Generic Environmental Impact Statement the Licensing of New Nuclear Reactors

Draft NUREG-2249, Generic Environmental Impact Statement for Licensing of New Nuclear Reactors.pdf

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

Generic Environmental Impact Statement the Licensing of New Nuclear Reactors

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NUREG-2249

Generic Environmental
Impact Statement for
Licensing of New
Nuclear Reactors
Draft Report for Comment

Office of Nuclear Material Safety and Safeguards

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NUREG-2249

Generic Environmental
Impact Statement for
Licensing of New
Nuclear Reactors
Draft Report for Comment
Manuscript Completed: September 2024
Date Published: September 2024

Office of Nuclear Material Safety and Safeguards

COMMENTS ON DRAFT REPORT
Any interested party may submit comments on this report for consideration by the NRC staff.
Comments may be accompanied by additional relevant information or supporting data. Please
specify the report number NUREG-2249 in your comments and send them by the end of the
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Do not provide information you would not want to be publicly available.

ABSTRACT

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The U.S. Nuclear Regulatory Commission (NRC) staff prepared this generic environmental
impact statement (GEIS) in accordance with the National Environmental Policy Act of 1969
(NEPA), as amended, to address the NRC licensing of the building and operation of new
nuclear reactors in the United States. In this GEIS, the NRC staff uses the values and
assumptions in a technology-neutral plant parameter envelope (PPE) for a new nuclear reactor
to evaluate the environmental impacts of constructing and operating a nuclear reactor. In
addition, this GEIS assumes that a new reactor might be built anywhere in the United States
and territories that meets the requirements of the NRC’s siting regulations. To accommodate
this broad range of siting possibilities, the staff developed a site parameter envelope (SPE) that
provides limiting values and assumptions related to the site.

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The purpose and need for this GEIS is to present impact analyses for the environmental issues
that are common to many new nuclear reactors 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 results from this
GEIS will be codified in Title 10 of the Code of Federal Regulations Part 51. Applicants
submitting licensing applications for new nuclear reactors may cite the regulation for those
issues bounded by the PPE and SPE and related values and assumptions rather than
presenting application-specific analyses. The NRC staff performing environmental reviews may
cite the analyses in this GEIS for those same issues instead of addressing the issues
individually in application-specific documentation. By developing this GEIS, the NRC staff
expects to streamline the time and effort needed to complete environmental reviews under
NEPA for most new nuclear reactors.

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This GEIS evaluates the potential environmental impacts of 122 issues relevant to building and
operation of a nuclear reactor. It identifies 100 issues as Category 1 issues. This number
includes issues for which potential environmental impacts have been generically determined to
be SMALL and adverse provided that the project is bounded by relevant PPE and SPE values
and assumptions, and issues for which the impacts are beneficial. The GEIS identifies 20 issues
as Category 2 issues and concludes that an application-specific analysis considering
site-specific conditions is necessary for those issues. Finally, as discussed in Section 1.3.3.3,
there are two issues that are designated as N/A (i.e., impacts are Uncertain), which are neither
Category 1 nor 2. Upon receipt of an application for a new nuclear reactor, the NRC staff would
prepare a supplemental environmental impact statement or other supplemental NEPA
documentation for the proposed project.

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In general, an application for a new nuclear reactor can refer to the generic analysis in this GEIS
for any Category 1 issue without further analysis, if it demonstrates that the relevant values and
assumptions in the PPE and SPE are met and there is no new and significant information to
change the conclusions in this GEIS. If the relevant parameters and assumptions for a
Category 1 issue are not met, the applicant would have to supply the requisite information
necessary for the staff to perform a site-specific analysis. Applicants addressing Category 2
issues would have to provide all of the information typically needed to perform a site-specific
analysis.

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The NRC staff also addresses a No-Action Alternative where the staff would not issue this GEIS
and would instead prepare individualized NEPA documentation when reviewing each incoming
new nuclear reactor licensing application. The NRC staff concluded that this alternative was not
environmentally preferable to the proposed action (development of this GEIS).

TABLE OF CONTENTS

ABSTRACT ................................................................................................................... iii

LIST OF FIGURES......................................................................................................... xi

LIST OF TABLES ........................................................................................................ xiii

EXECUTIVE SUMMARY .............................................................................................. xv

ABBREVIATIONS AND ACRONYMS ......................................................................... xxi

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INTRODUCTION ................................................................................................. 1-1
1.1
1.2
1.3

1.4

Purpose and Need for this GEIS ..........................................................................1-2
NEPA Process .....................................................................................................1-2
Analytical Approach Used in this GEIS ................................................................1-3
1.3.1
Methodology .........................................................................................1-3
1.3.2
Primary Documents Used to Develop this GEIS ....................................1-8
1.3.3
Issue Categories ...................................................................................1-9
1.3.3.1
Category 1 Issues – Generic Analysis ................................1-9
1.3.3.2
Category 2 Issues – Project-Specific Analysis ....................1-9
1.3.3.3
Uncertain Issues ...............................................................1-13
Implementation of the Rule (10 CFR Part 51) ....................................................1-18
1.4.1
General Requirements ........................................................................1-19
1.4.2
Applicant’s Environmental Report .......................................................1-19
1.4.3
The NRC’s SEIS .................................................................................1-19
1.4.4
Public Scoping and Public Comments .................................................1-19
1.4.5
The NRC’s Draft SEIS .........................................................................1-20
1.4.6
The NRC’s Final SEIS .........................................................................1-20

DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES ..................... 2-1
2.1

Proposed Action and Alternatives to the GEIS .....................................................2-1
2.1.1
Proposed Action: Issue Technology-Neutral GEIS Based on
Performance-Based Assumptions .........................................................2-1
2.1.2
No-Action Alternative: No GEIS – Project-Specific National
Environmental Policy Act Review Only ..................................................2-2
2.1.3
Other Alternatives Considered but Not Analyzed in Detail .....................2-2
2.1.3.1
Limiting the GEIS to Reactors Less than 30 MWt ...............2-2
2.1.3.2
GEIS for Advanced Nuclear Reactors Only ........................2-2
2.1.3.3
GEIS Analyzing All Potential Environmental Impacts ..........2-3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ...... 3-1
3.1

Land Use .............................................................................................................3-2

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3.1.1
3.1.2

3.2

3.3

3.4

3.5

3.6

3.7

3.8

Baseline Conditions and PPE/SPE Values and Assumptions ................3-2
Land Use Impacts .................................................................................3-4
3.1.2.1
Environmental Consequences of Construction ...................3-5
3.1.2.2
Environmental Consequences of Operation........................3-9
Visual Resources ...............................................................................................3-11
3.2.1
Baseline Conditions and PPE/SPE Values and Assumptions ..............3-11
3.2.2
Visual Resources Impacts ...................................................................3-11
3.2.2.1
Environmental Consequences of Construction .................3-12
3.2.2.2
Environmental Consequences of Operation......................3-14
Meteorology and Air Quality ...............................................................................3-15
3.3.1
Baseline Conditions and PPE/SPE Values and Assumptions ..............3-15
3.3.2
Air Quality Impacts ..............................................................................3-18
3.3.2.1
Environmental Consequences of Construction .................3-20
3.3.2.2
Environmental Consequences of Operation......................3-22
Water Resources ...............................................................................................3-26
3.4.1
Baseline Conditions and PPE/SPE Values and Assumptions ..............3-26
3.4.1.1
Surface Water Resources.................................................3-28
3.4.1.2
Groundwater Resources ...................................................3-30
3.4.2
Water Resources Impacts ...................................................................3-33
3.4.2.1
Environmental Consequences of Construction .................3-33
3.4.2.2
Environmental Consequences of Operation......................3-42
Terrestrial Ecology .............................................................................................3-58
3.5.1
Baseline Conditions and PPE/SPE Values and Assumptions ..............3-58
3.5.2
Terrestrial Ecology Impacts .................................................................3-60
3.5.2.1
Environmental Consequences of Construction .................3-61
3.5.2.2
Environmental Consequences of Operation......................3-71
Aquatic Ecology .................................................................................................3-82
3.6.1
Baseline Conditions and PPE/SPE Values and Assumptions ..............3-82
3.6.2
Aquatic Ecology Impacts .....................................................................3-84
3.6.2.1
Environmental Consequences of Construction .................3-84
3.6.2.2
Environmental Consequences of Operation......................3-90
Historic and Cultural Resources.........................................................................3-99
3.7.1
Baseline Conditions ............................................................................3-99
3.7.1.1
National Historic Preservation Act and NEPA .................3-100
3.7.2
Historic and Cultural Resources Impacts ...........................................3-101
3.7.2.1
Environmental Consequences of Construction ...............3-101
3.7.2.2
Environmental Consequences of Operation....................3-102
Environmental Hazards....................................................................................3-103
3.8.1
Radiological Environment..................................................................3-103
3.8.1.1
Baseline Conditions and PPE/SPE Values and
Assumptions ...................................................................3-103

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3.9

3.10

3.11

3.12

3.13

3.8.1.2
Radiological Environment Impacts..................................3-108
3.8.2
Nonradiological Environment............................................................. 3-117
3.8.2.1
Baseline Conditions and PPE/SPE Values and
Assumptions ...................................................................3-117
3.8.2.2
Nonradiological Environment Impacts............................. 3-119
Noise ...............................................................................................................3-124
3.9.1
Baseline Conditions and PPE/SPE Values and Assumptions ............3-124
3.9.2
Noise Impacts ...................................................................................3-125
3.9.2.1
Environmental Consequences of Construction ...............3-125
3.9.2.2
Environmental Consequences of Operation....................3-125
Waste Management......................................................................................... 3-126
3.10.1 Radiological Waste Management ......................................................3-126
3.10.1.1
Baseline Conditions and PPE/SPE Values and
Assumptions ...................................................................3-126
3.10.1.2
Radiological Waste Impacts ...........................................3-129
3.10.2 Nonradiological Waste Management .................................................3-131
3.10.2.1
Baseline Conditions and PPE/SPE Values .....................3-131
3.10.2.2
Nonradiological Waste Impacts ......................................3-132
Postulated Accidents ....................................................................................... 3-135
3.11.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-135
3.11.1.1
Design Basis Accidents Involving Radiological
Releases ........................................................................3-135
3.11.1.2
Accidents Involving Releases of Hazardous
Chemicals ......................................................................3-135
3.11.1.3
Severe Accidents ........................................................... 3-137
3.11.1.4
Severe Accident Mitigation Design Alternatives ..............3-138
3.11.1.5
Acts of Terrorism ............................................................ 3-139
3.11.2 Postulated Accidents Impacts ........................................................... 3-140
3.11.2.1
Design Basis Accidents Involving Radiological
Releases ........................................................................3-141
3.11.2.2
Accidents Involving Releases of Hazardous
Chemicals ......................................................................3-141
3.11.2.3
Severe Accidents ........................................................... 3-142
3.11.2.4
Severe Accident Mitigation Design Alternatives ..............3-142
3.11.2.5
Acts of Terrorism ............................................................ 3-142
Socioeconomics .............................................................................................. 3-143
3.12.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-143
3.12.2 Socioeconomic Impacts ....................................................................3-144
3.12.2.1
Socioeconomic Consequences of Construction ..............3-144
3.12.2.2
Socioeconomic Consequences of Operations ................3-148
Environmental Justice ......................................................................................3-150
3.13.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-150

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3.13.2

3.14

3.15

Environmental Justice Impacts .......................................................... 3-151
3.13.2.1
Environmental Consequences of Construction and
Operation .......................................................................3-151
Fuel Cycle........................................................................................................3-151
3.14.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-151
3.14.1.1
Uranium Fuel Cycle Environmental Data ........................ 3-151
3.14.1.2
Other Fissile Fuel Cycles ................................................3-153
3.14.1.3
DOE High-Assay Low-Enriched Uranium Availability
Program .........................................................................3-154
3.14.1.4
Nuclear Fuel Cycle Regulatory Requirements for New
Reactors .........................................................................3-154
3.14.1.5
Changes in the Nuclear Fuel Cycle since WASH-1248 ...3-155
3.14.1.6
PPE Assumptions ........................................................... 3-156
3.14.2 Fuel Cycle Impacts............................................................................3-157
3.14.2.1
Uranium Recovery .......................................................... 3-157
3.14.2.2
Uranium Conversion ....................................................... 3-159
3.14.2.3
Enrichment .....................................................................3-160
3.14.2.4
Fuel Fabrication.............................................................. 3-161
3.14.2.5
Reprocessing .................................................................3-168
3.14.2.6
Storage and Disposal of Radiological Wastes ................3-170
3.14.3 Staff Conclusions about the Environmental Impacts of a New
Reactor Fuel Cycle............................................................................3-175
Transportation of Fuel and Waste ....................................................................3-176
3.15.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-176
3.15.1.1
Table S-4 on the Transportation of Fuel and Waste ........3-176
3.15.1.2
Additional NRC Studies of the Risk from the
Transportation of SNF ....................................................3-177
3.15.1.3
Additional NRC Information Sources .............................. 3-179
3.15.1.4
U.S. Department of Energy Transportation Risk
Assessments ..................................................................3-179
3.15.1.5
Issues for the Transportation of Non-LWR Fuel and
Wastes ...........................................................................3-179
3.15.1.6
Development of the Transportation Plant Parameter
Envelope ........................................................................3-180
3.15.1.7
Transportation of Unirradiated New Reactor Fuel ...........3-182
3.15.1.8
Transportation of Radioactive Waste from New
Reactors .........................................................................3-187
3.15.1.9
Transportation of SNF from New Reactors .....................3-193
3.15.2 Transportation Impacts......................................................................3-199
3.15.2.1
Transportation of Unirradiated New Reactor Fuel ...........3-200
3.15.2.2
Transportation of Radioactive Waste from New
Reactors .........................................................................3-201
3.15.2.3
Transportation of Irradiated Fuel from New Reactors .....3-202

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3.16

Decommissioning ............................................................................................ 3-203
3.16.1 Baseline Conditions and PPE/SPE Values and Assumptions ............3-203
3.16.2 Decommissioning Impacts ................................................................ 3-205

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SUMMARY OF FINDINGS .................................................................................. 4-1

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APPENDIX A

CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT
STATEMENT ..................................................................................... A-1

APPENDIX B

OUTREACH ...................................................................................... B-1

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APPENDIX C

CHRONOLOGY OF NRC STAFF ENVIRONMENTAL REVIEW
CORRESPONDENCE RELATED TO THE ADVANCED
REACTOR GENERIC ENVIRONMENTAL IMPACT STATEMENT .. C-1

APPENDIX D

DISTRIBUTION LIST ........................................................................ D-1

APPENDIX E

COMMENTS ON THE GEIS ...............................................................E-1

APPENDIX F

LAWS, REGULATIONS, AND OTHER AUTHORIZATIONS ............. F-1

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APPENDIX G PLANT PARAMETER ENVELOPE AND SITE PARAMETER
ENVELOPE ....................................................................................... G-1

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APPENDIX H

4.1
4.2
4.3
4.4

Unavoidable Adverse Environmental Impacts and Irreversible and
Irretrievable Commitments of Resources ...........................................................4-28
Relationship between Short-Term Use of the Environment and Long-Term
Productivity ........................................................................................................4-28
No-Action Alternative Conclusion.......................................................................4-29
Cost Benefit .......................................................................................................4-29

REFERENCES .................................................................................................... 5-1

GREENHOUSE GAS EMISSIONS ESTIMATES FOR A
REFERENCE 1,000 MWE REACTOR .............................................. H-1

LIST OF FIGURES

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Figure 3-1

Figure 3-2
Figure 3-3
Figure 3-4

SMALL Surface Water Use Impacts for Plant Withdrawals of 6,000 gpm or
Less Compared to the 95 Percent Exceedance Discharge in the Flowing
Surface Water Body ........................................................................................3-45
Representative Radiological Exposure Pathways to Human. ........................ 3-106
Representative Radiological Exposure Pathways to Nonhuman Biota. .........3-107
Options of the Current Fuel Cycle which Includes the Table S-3 Uranium
Fuel Cycle .....................................................................................................3-153

LIST OF TABLES

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Table 1-1
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 3-5
Table 3-6
Table 3-7
Table 3-8
Table 3-9
Table 3-10
Table 3-11
Table 3-12
Table 3-13
Table 3-14
Table 3-15
Table 3-16
Table 3-17
Table 3-18
Table 3-19
Table 3-20
Table 4-1

Issues Discussed in the Generic Environmental Impact Statement .................1-13
Plant Parameter Envelope Values for Greenhouse Gas Emissions.................3-19
Construction Worker Individual and Collective Doses ...................................3-109
Maximally Exposed Individual Doses ............................................................ 3-112
Total Population and Collective Natural Background Doses in
50 mi Radius .................................................................................................3-114
Aquatic Nonhuman Biota Doses ...................................................................3-116
Terrestrial Nonhuman Biota Doses ............................................................... 3-116
Level of Service Value Descriptions .............................................................. 3-146
Light-Water Reactor Fuel Fabrication Capacity .............................................3-162
WASH-1248 Fuel Fabrication Environmental Impacts ...................................3-163
Number of Truck Shipments and One-Way Shipping Distances for
Unirradiated Fuel .......................................................................................... 3-184
Radiological Impacts Under Normal Conditions of Transporting
Unirradiated Fuel from WASH-1238 and New Reactor Sites ......................... 3-185
Nonradiological Impacts of Transporting Unirradiated Fuel ........................... 3-187
Summary of Radioactive Waste Shipments and One-Way Shipping
Distances ......................................................................................................3-189
Low-Level Radioactive Waste by Volume .....................................................3-190
Low-Level Radioactive Waste by Activity ......................................................3-191
Annual Nonradiological Impacts of Transporting Waste from the Site ...........3-193
Incident-Free Radiological Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site .....................................................................................3-195
Radiological Accident Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site .....................................................................................3-196
Nonradiological Accident Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site .....................................................................................3-197
Summary of the Environmental Impacts from Decommissioning Nuclear
Power Facilities ............................................................................................. 3-206
Summary of Findings and Mitigation .................................................................4-2

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EXECUTIVE SUMMARY

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In recent years, interest in developing and licensing new nuclear reactors, including advanced
nuclear reactors (ANRs)1, in the United States using new technologies has increased. The
increased interest is demonstrated by the Nuclear Energy Innovation Capabilities Act of 2017
(Public Law 115-248) and Nuclear Energy Innovation and Modernization Act of 2019 (Public
Law 115-439). On November 15, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff
issued a Federal Register notice (84 FR 62559) announcing an exploratory process and
soliciting comments to determine the possible utility of developing a generic environmental
impact statement (GEIS) for licensing ANRs.

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In a GEIS, the NRC staff evaluates environmental impacts common to a group of related future
licensing actions, thereby allowing the staff to focus on impacts requiring consideration of
project-specific and site-specific factors once applications are received. As part of the
exploratory process, the staff considered its experience with previous GEIS documents
developed by NRC staff for power reactor license renewals, in situ uranium recovery facilities,
and decommissioning. The NRC issued a notice of intent to prepare the GEIS on April 30, 2020
(85 FR 24040), carried out a scoping process, and held a scoping meeting to receive public
comments on the GEIS on May 28, 2020. After considering the comments received from
interested stakeholders and the public during the scoping process, the NRC staff developed this
GEIS as a document that would be applicable to ANRs only.

20
21
22
23
24
25

The GEIS was developed initially using a technology-neutral, performance-based approach to
allow its use by a wide range of future ANR applicants. In Staff Requirements Memorandum
(SRM) SECY-20-0020, dated September 21, 2020, (NRC 2020-TN6492), the Commission
approved the development of a GEIS for the construction and operation of ANRs using a
technology-neutral, performance-based approach, and directed staff to codify results in the
Code of Federal Regulations (CFR).

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28
29
30
31
32

In SRM SECY-21-0098, dated April 17, 2024, the Commission directed the NRC staff to change
the limited applicability of this GEIS from solely “advanced nuclear reactors” to any new nuclear
reactor licensing application, provided the application meets the values and the assumptions of
the plant parameter envelopes and the site parameter envelopes used to develop the GEIS.
The term “nuclear reactor,” as it is used in this GEIS, is defined in 10 CFR 50.2 as “an
apparatus, other than an atomic weapon, designed or used to sustain nuclear fission in a
self-supporting chain reaction.”

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34
35

In SRM SECY-23-0001, dated April 13, 2023, the Commission directed the staff to regulate
near-term fusion systems under the 10 CFR Part 30 byproduct material framework. Therefore,
this GEIS does not address the environmental impacts of fusion systems.

ES.1

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39

Purpose and Need for this GEIS

A definition for an ANR is provided in the Nuclear Energy Innovation and Modernization Act of 2019
(Public Law 115-439). ANRs are a subset of the broader range of new nuclear reactors addressed by this
GEIS.

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2
3
4
5
6
7

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. This GEIS is intended to improve the
efficiency of licensing new nuclear reactors by (1) identifying the possible types of
environmental impacts of constructing and operating a nuclear reactor, (2) assessing impacts
that are expected to be generic (the same or similar) for many nuclear reactors, and (3) defining
the environmental issues that will need to be addressed in project-specific supplemental
environmental impact statements (SEISs) addressing specific projects.

ES.2

Proposed Action

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15

The proposed action is for the NRC staff to use a technology-neutral approach to issue a GEIS
that identifies and analyzes environmental issues, common to building and operation of a
nuclear reactor, for which a generic determination that impacts would not be environmentally
significant is possible as long as specific reasonable and practicable values and assumptions
are met. Values and assumptions regarding the design of the plant are termed the plant
parameter envelope (PPE) and values and assumptions regarding site conditions are termed
the site parameter envelope (SPE). The results of this GEIS will be codified in 10 CFR Part 51.

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20
21
22

To develop this GEIS, the NRC established an interdisciplinary team of environmental subject
matter experts (SMEs) from the NRC and from contractor Pacific Northwest National
Laboratory—all of whom have extensive experience in evaluating the environmental impacts of
new reactors. In the GEIS, the interdisciplinary team is collectively referred to as the NRC staff.
The SMEs included individuals who have expertise in nuclear technology, radiation protection,
land use, aquatic and terrestrial ecology, hydrology and water use, socioeconomics,
environmental justice, meteorology and air quality, and human health.

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34

Because new nuclear reactors are likely to include a range of reactor designs and could be sited
anywhere in the United States and territories that meets NRC siting requirements, the NRC
pursued a technology-neutral approach using assumptions contained in the PPE and SPE
(Appendix G). The PPE consists of bounding values or parameters for reactor design features
regardless of the site. In addition, the staff developed an SPE table of site conditions and
assumptions. The table includes the site size, size of water bodies supplying water to the
reactor, and demographics of the region surrounding the site, as well as specific assumptions
related to the condition of the affected environment, such as the extent and occurrence of
wetlands and floodplains, site position relative to aquatic features, and its proximity to sensitive
noise receptors. This GEIS 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 for
those issues for which a generic conclusion was possible (referred to as Category 1 issues).

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The environmental issues are organized into 16 environmental resources. Each issue
corresponds to a specific type of environmental impact determined by the interdisciplinary team
of SMEs to potentially result from building or operation of a nuclear reactor. This GEIS will allow
licensing applications for new nuclear reactors to reference the generic analysis for each
Category 1 environmental issue for which it can demonstrate that the project is bounded by the
applicable assumptions in the PPE and SPE and for which there is no new and significant
information affecting the evaluation. The NRC staff would have to prepare a SEIS or other
supplemental National Environmental Policy Act of 1969, as amended (NEPA) documentation
for the licensing of a new nuclear reactor, if using this GEIS. The SEIS would briefly describe
how the project meets the PPE and SPE values and assumptions for the appropriate
Category 1 issues. The SEIS would also evaluate the environmental impacts of any issues for

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which an application cannot demonstrate that the relevant assumptions in the PPE and SPE are
met, as well as issues that the staff could not address generically in this GEIS.

ES.3

4
5
6
7
8
9

For each issue, the SMEs identified each value or assumption in the PPE and SPE that could
effectively bound a meaningful generic analysis. The SMEs performed and described generic
analyses for each issue for a hypothetical reactor that falls within the bounding values of the
PPE on a site that falls within the bounding values of the SPE. The SMEs drew conclusions
about each analysis using one of the three significance levels that the NRC staff typically uses
in environmental impact statements (EISs) for new reactors:

Impact Significance Levels and Categorization of Issues

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12
13

• SMALL – Environmental effects that are not detectable or are so minor that they will neither
destabilize nor noticeably alter any important attribute of the resource. For the purposes of
assessing radiological impacts, the Commission has concluded that those impacts that do
not exceed permissible levels in the Commission’s regulations are considered SMALL.

14
15

• MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize,
important attributes of the resource.

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17

• LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize
important attributes of the resource.

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19

These significance levels follow the definitions presented in the footnotes to Table B-1 in
Appendix B to Subpart A of 10 CFR Part 51.

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21
22
23

The SMEs assigned each issue to one of two categories depending on the potential utility of the
generic analysis to applicants preparing specific new nuclear reactor licensing applications and
to the NRC staff when completing environmental reviews of those applications. The categories
are as follows:

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25
26

• Category 1 issues – environmental issues for which a generic analysis concluding SMALL
adverse environmental impacts is possible, provided that relevant values and assumptions
in the PPE and SPE are met, or beneficial impacts;

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28
29

• Category 2 issues – environmental issues for which a meaningful generic analysis of
environmental impacts is not possible because the issue requires consideration of projectspecific information.

30
31

In addition, as discussed in Section 1.3.3.3, there are two issues that are designated as N/A
(i.e., impacts are Uncertain), which are neither Category 1 nor 2.

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34
35
36
37
38
39

An applicant addressing a Category 1 issue in its environmental report (ER) that accompanies
an application may refer to the generic analysis in this GEIS for that issue without further
analysis, provided that it demonstrates that the relevant assumptions in the PPE and SPE are
met and there is no new and significant information to change the conclusions in this GEIS. If
the relevant parameters and assumptions for a Category 1 issue are not met, the applicant
would have to supply the requisite information necessary for the staff to perform a site-specific
analysis. All applicants would have to individually address each Category 2 issue without
reference to this GEIS.

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3

This GEIS also identifies other elements of environmental documentation that must be
addressed individually, including sections addressing the purpose and need, need for power (or
project), and alternatives to the proposed action.

ES.4

Alternatives

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19

In addition to the proposed action of preparing a GEIS for new nuclear reactors, the NRC staff
analyzed a No-Action Alternative in which the NRC does not issue this GEIS. Without the
availability of this GEIS, applicants for licensing new nuclear reactors would have to address all
relevant environmental issues individually in their ERs, and staff would have to prepare
individual EISs for each application received that address all relevant environmental issues
(including all Category 1 and Category 2 issues). The processes for an applicant to prepare an
ER and for the NRC staff to prepare an EIS would remain those used in the past for new reactor
licensing applications. Conclusions in this GEIS regarding potential environmental impacts could
not be referenced. However, the No-Action Alternative would accomplish none of the benefits
intended by the preparation of this GEIS, which would include (1) reducing the time and
resources for the applicant’s preparation of the environmental report, (2) reducing the time and
resources for the NRC staff’s preparation of the EIS and (3) focusing the resources of the
applicant, NRC staff, and decision-makers on issues where there is truly a potential for
significant environmental impacts. The NRC staff therefore concludes that the No-Action
Alternative is not preferable to the proposed action.

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22
23
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26
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28
29
30
31
32
33
34
35

Prior to scoping, the NRC staff contemplated preparing a GEIS that would analyze the potential
environmental impacts of a hypothetical reactor that would have a power level of approximately
30 megawatts thermal or less on a hypothetical site. The analytical approach to developing this
GEIS would have been similar to that used under the proposed action, but the PPE/SPE would
have been developed based on a typical reactor of 30 megawatts thermal, limiting the range of
reactors for which this GEIS would have been useful. Use of the power-level–based GEIS by
applicants for small reactors and NRC staff would have been the same as for the environmental
performance-based GEIS called for in the proposed action. During scoping, multiple
commenters suggested that the parameters used in the generic analyses should be tied to the
potential for environmental impacts rather than to an arbitrary power level. After reviewing the
comments, the staff agreed that a GEIS developed using technology-neutral performancebased values and assumptions tied to environmental impacts might help streamline
environmental reviews even for some larger ANRs that have a low potential for significant
environmental impacts with respect to some environmental issues. Because of the limited utility
of a GEIS based on a limited power level, the staff decided not to evaluate this alternative
approach in detail.

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38
39
40
41
42
43
44

The NRC staff initially developed this GEIS as a document that would be applicable to only
ANRs. See SECY-21-0098, Proposed Rule: Advanced Nuclear Reactor Generic Environmental
Impact Statement, dated November 29, 2021. However, in SRM SECY-21-0098, dated April 17,
2024, the Commission directed the NRC staff to change the limited applicability of this GEIS
from solely “advanced nuclear reactors” to any new nuclear reactor licensing application,
provided the application meets the values and the assumptions of the plant parameter
envelopes and the site parameter envelopes used to develop the GEIS. Based on the direction
from the Commission, the alternative of developing a GEIS that would be applicable to only
advanced nuclear reactors will not be considered further.

xviii

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3
4
5
6
7
8
9

The staff also considered whether it would be possible to develop a GEIS that could serve as
the sole technical documentation of potential environmental impacts for any new nuclear
reactor. However, the staff concluded that it is not technically possible to develop generic
analyses addressing all potentially significant environmental impacts from any new nuclear
reactor without consideration of project-specific and site-specific conditions. It is also unrealistic
to assume that a GEIS would be able to fully comply with other environmental laws such as the
Endangered Species Act (16 U.S.C. §§ 1531 et seq.) or the National Historic Preservation Act
(54 U.S.C. §§ 300101 et seq.). Therefore, the staff decided not to evaluate this alternative
approach in detail.

ES.5

Affected Environment and Environmental Consequences

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16
17
18
19
20
21
22
23

The baseline condition described as the “affected environment” in this GEIS is the environment
that exists at a site proposed for building and operation of a nuclear reactor. The site could be
anywhere in the United States or its territories that meets the NRC reactor siting criteria in
10 CFR Part 100. The affected environment reflects the existing condition of environmental
resources, as influenced by natural physical conditions and by past human activities such as
agriculture, forestry, mining, urbanization, and industrial and non-industrial development. The
range of existing environmental conditions that might possibly occur at a proposed site located
anywhere in the United States is too broad to characterize. To address this, the NRC staff
developed the PPE, SPE, and related assumptions presented in Appendix G. The PPE and
SPE contain assumptions regarding the absence of, or limited presence of, sensitive
environmental resources such as sensitive habitats, wetlands, floodplains, and residences on or
near the site. The PPE and SPE also contain assumptions regarding the size and condition of
resources near the site, including water sources and air.

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26
27
28
29
30
31
32

The NRC staff evaluated the potential environmental impacts from 122 issues in 16
environmental resources in this GEIS. Of these, the staff identified 100 issues as Category 1
issues and 20 issues as Category 2 issues (Table 4-1). In addition, as discussed in
Section 1.3.3.3, there are two issues that are designated as N/A (i.e., impacts are Uncertain),
which are neither Category 1 nor 2. The NRC staff determined that the potential environmental
impacts for each Category 1 issue would be of SMALL significance, as long as the applicable
assumptions in the PPE and SPE are met. The basis for identifying an issue as a Category 1
issue is whether a generic analysis of the issue is sufficient for decision-makers and the public
when licensing a new nuclear reactor that meets the assumptions in the PPE and SPE.

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38
39
40
41
42
43
44
45
46
47

The NRC staff determined that it is not possible to evaluate the significance of environmental
impacts from the Category 2 issues without application-specific evaluation after receiving a
licensing application that identifies specific design parameters and site conditions. The staff
identified certain issues as Category 2 issues because they require project-specific consultation
with outside agencies to comply with statutes other than NEPA. Examples include issues
related to threatened or endangered species regulated under the Endangered Species Act,
essential fish habitat regulated under the Magnuson-Stevens Fishery Conservation and
Management Act, and historic properties regulated under the National Historic Preservation Act.
The staff is unable to evaluate the significance of impacts on those resources without receiving
technical input from the consultations. The staff identified certain other issues as Category 2
issues because it was not possible to set realistic assumptions that could underlie a conclusion
that the impacts would necessarily be SMALL at any hypothetical site in the United States.
However, the fact that an individualized analysis is necessary does not mean that the
supplemental NEPA documentation will lead the NRC staff to conclude that impacts pertaining
to the issue will be greater than SMALL; it only means that more than a generic analysis is

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3
4

necessary to reach a conclusion. Although it would theoretically be possible to constrain the
assumptions to the extent that impacts on almost any environmental impact would be SMALL,
the NRC staff intends for this new reactor GEIS to be a practicable, usable document for
different types of new reactor projects.

ABBREVIATIONS AND ACRONYMS

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3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40

°C
°F
235

degree(s) Celsius
degree(s) Fahrenheit
uranium-235

ac
ACHP
ADAMS
ADU
ALARA
AEC
AEGL
APE
APLIC
ARE
ATF

acre(s)
Advisory Council on Historic Preservation
Agencywide Documents Access and Management System
ammonium diuranate
as low as is reasonably achievable
Atomic Energy Commission
Acute Exposure Guideline Level
area of potential effect
Avian Power Line Interaction Committee
Aircraft Reactor Experiment
accident tolerant fuel

BMP
Bq
BWXT

best management practice
becquerel(s)
BWX Technologies, Inc.

CAA
CDF
CEQ
CERCLA
CFR
CH4
Ci
CISF
CO
CO2
CO2(e)
COL
CP
CWA
CZMA

Clean Air Act
core damage frequency
Council on Environmental Quality
Comprehensive Environmental Response, Compensation, and Liability
Act (Superfund)
Code of Federal Regulations
methane
curie(s)
Consolidated Interim Storage Facility
carbon monoxide
carbon dioxide
CO2 equivalent
combined construction permit and operating license or combined license
construction permit
Clean Water Act (aka Federal Water Pollution Control Act)
Coastal Zone Management Act

d
dBA

day(s)
decibel(s) on the A-weighted scale

xxi

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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41

DBA
DCP
DOE
DOT
DTS

design basis accident
dry conversion process
U.S. Department of Energy
U.S. Department of Transportation
dry transfer system

EA
EBR-II
EIS
EJ
EMF
EPA
ER
ESA
ESP

environmental assessment
Experimental Breeder Reactor-II
environmental impact statement
environmental justice
electromagnetic field
U.S. Environmental Protection Agency
environmental report
Endangered Species Act of 1973, as amended
early site permit

FAST
FEIS
FPPA
FSAR
ft
ft2
ft3
FWS

Fixing America’s Surface Transportation Act
final environmental impact statement
Farmland Protection Policy Act
Final Safety Analysis Report
foot or feet
square foot or feet
cubic foot or feet
U.S. Fish and Wildlife Service

g
gal
GEIS
GHG
gpd
gpm
GTCC
GWd
Gy

gram(s)
gallon(s)
generic environmental impact statement
greenhouse gas
gallon(s) per day
gallon(s) per minute
greater than Class C
gigawatt day(s)
gray(s)

ha
HALEU
HAP
HEU
HLW
hr

hectare(s)
high-assay low- enriched uranium
hazardous air pollutant
highly enriched uranium
high-level waste
hour(s)

xxii

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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41

hertz

IAEA
ICRP
in.
INL
IPCC
ISFSI
ISG

International Atomic Energy Agency
International Commission on Radiological Protection
inch(es)
Idaho National Laboratory
Intergovernmental Panel on Climate Change
independent spent fuel storage installation
Interim Staff Guidance

kg
km
km2
kV
kWh

kilogram(s)
kilometer(s)
square kilometer(s)
kilovolt(s)
kilowatt-hour(s)

L
lb
LEU
LLC
LLRW
LOS
LWR

liter(s)
pound(s)
low-enriched uranium
Limited Liability Company
low-level radioactive waste
level of service
light-water reactor

m
m3
MEI
mGy
mi
mi2
MIMS
M
MMT
mo
mrad
mrem
MSR
MSRE
MT
MTU
MW

meter(s)
cubic meter(s)
maximally exposed individual
milligray(s)
mile(s)
square mile(s)
Manifest Information Management System
million
million metric tons
month(s)
millirad(s)
millirem(s)
molten-salt reactor
Molten-Salt Reactor Experiment
metric ton(nes)
metric ton(nes) uranium
megawatt(s)

xxiii

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8
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12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41

MWe
MWt
MWd
MWd/MTU
MWh

megawatt(s) electrical
megawatt(s) thermal
megawatt-day(s)
megawatt-day(s) per metric ton of uranium
megawatt-hour(s)

N/A
N2O
NAAQS
NCRP
NEI
NEIMA
NEPA
NHPA
NMFS
NOx
NPDES
NR
NR GEIS
NRC
NRHP
NRIC
NUREG
NWP

not applicable
nitrous oxide
National Ambient Air Quality Standard
National Council on Radiation Protection and Measurements
Nuclear Electric Institute
Nuclear Energy Innovation and Modernization Act of 2019
National Environmental Policy Act of 1969, as amended
National Historic Preservation Act
National Marine Fisheries Service
oxides of nitrogen
National Pollutant Discharge Elimination System
nuclear reactor
Generic Environmental Impact Statement for Licensing New Nuclear
Reactors
U.S. Nuclear Regulatory Commission
National Register of Historic Places
National Reactor Innovation Center
U.S. Nuclear Regulatory Commission technical document
Nation Wide Permit

OSHA

Occupational Safety and Health Administration

PA
PER
PFSF
PM
PM10
PM2.5
PNNL
PPE
ppt
PRA
PSAR
PSDAR
PSEG

Programmatic Agreement
pyrochemical/electrochemical reprocessing
Private Fuel Storage Facility
particulate matter
particulate matter with a mean aerodynamic diameter of 10 μm or less
particulate matter with a mean aerodynamic diameter of 2.5 μm or less
Pacific Northwest National Laboratory
plant parameter envelope
part(s) per thousand
probabilistic risk assessment
Preliminary Safety Analysis Report
post-shutdown decommissioning activity report
Public Service Enterprise Group

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7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41

PUREX
PWR

plutonium uranium extraction
pressurized water reactor

RCRA
REMP
RG
RMP
ROW
RRY
Ryr

Resource Conservation and Recovery Act of 1976, as amended
Radiological Environmental Monitoring Program
Regulatory Guide
Risk Management Plan
right-of-way
reference reactor-year
reactor-year(s)

s or sec
SAFSTOR
SAMA
SAMDA
SDWA
SEIS
SHPO
SME
SMR
SNF
SNM
SOx
SPE
SRM
SRP
SSA
SWU

second(s)
SAFe STORage
severe accident mitigation alternative
severe accident mitigation design alternative
Safe Drinking Water Act
supplemental environmental impact statement
State Historic Preservation Office
subject matter expert
small modular reactor
spent nuclear fuel
special nuclear material
oxides of sulfur
site parameter envelope
Staff Requirements Memorandum
standard review plan
Sole Source Aquifer
separative work unit

T
TCP
TDS
TEDE
Th-232
THPO
TPQ
TQ
TRISO
TRU

ton(nes)
traditional cultural properties
total dissolved solids
total effective dose equivalent
thorium-232
Tribal Historic Preservation Office
Threshold Planning Quantity
threshold quantity
TRi-structural ISOtropic
transuranic

U-235

uranium-235

xxv

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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17

U-238
UF6
U.S.
UO2
USACE
USBR
U.S.C.
USDA
USNC

uranium-238
uranium hexafluoride
United States of America
uranium dioxide
U.S. Army Corps of Engineers
U.S. Bureau of Reclamation
United States Code
U.S. Department of Agriculture
Ultra Safe Nuclear Corporation

VOC

volatile organic compound

WCS
WNA

Waste Control Specialists, LLC
World Nuclear Association

yd3
yr

cubic yard(s)
year(s)

xxvi

INTRODUCTION

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17
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19

In recent years, interest in developing and licensing new nuclear reactors, including advanced
nuclear reactors (ANRs), in the United States using new technologies has increased. The
increased interest is demonstrated by the Nuclear Energy Innovation Capabilities Act of 2017
(Public Law 115-248; TN6468) and Nuclear Energy Innovation and Modernization Act of 2019
(NEIMA, Public Law 115-439; TN6469). One purpose of NEIMA is to provide a program for
developing “the expertise and regulatory processes necessary to allow innovation and
commercialization of advanced nuclear reactors.” A strategic nonprofit organization dedicated to
advancing nuclear development in the United States, ClearPath, sent a letter, dated February
19, 2019, to the U.S. Nuclear Regulatory Commission (NRC) recommending that it develop a
generic environmental impact statement (GEIS) for construction and operation of ANRs
(ClearPath 2019-TN6466). Multiple representatives of Congress also expressed interest in
having the NRC develop such a GEIS. On June 25, 2019, Senators Barrasso and Braun sent a
letter to the Chairman of the NRC requesting that the NRC initiate a process to develop a GEIS
for ANRs (Barrasso and Braun 2019-TN6465). The Chairman responded on July 29, 2019
(NRC 2019-TN6467) that the NRC would explore whether development of a GEIS would
beneficially streamline environmental reviews for ANRs while still fulfilling NRC’s responsibilities
to protect the environment and comply with the National Environmental Policy Act of 1969
(NEPA; 42 U.S.C. §§ 4321 et seq.; TN661).

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On November 15, 2019, the NRC staff issued a Federal Register notice (84 FR 62559-TN6470)
announcing an exploratory process and soliciting comments to determine the possible utility of
developing a GEIS for licensing ANRs. The exploratory process included two public meetings, a
comprehensive public workshop attended by multiple stakeholders, and a site visit to the Idaho
National Laboratory, one location that is being contemplated for some ANRs. As part of the
exploratory process, the staff considered its experience with previous NRC GEIS documents
that support power reactor license renewals, in situ uranium recovery facilities, and
decommissioning. The staff gathered information to determine whether a GEIS for construction
and operation of ANRs might be viable. The exploratory process concluded with an information
paper to the NRC Commission concluding that the staff decided to pursue a GEIS using a
technology-neutral approach, and that a GEIS would generically resolve many environmental
issues, saving resources and providing predictability for potential applicants.

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40

In Staff Requirements Memorandum (SRM) SECY-20-0020, dated September 21, 2020,
(NRC 2020-TN6492), the Commission approved the development of a GEIS for the construction
and operation of ANRs using a technology-neutral, performance-based approach, and directed
staff to codify results in the Code of Federal Regulations. Details of this approach are discussed
in Section 1.3. The NRC issued a notice of intent to prepare the GEIS on April 30, 2020 (85 FR
24040), carried out a scoping process, and held a scoping meeting to receive public comments
on the GEIS on May 28, 2020. After considering the comments received from various sources
during the scoping process, the NRC staff initially developed this GEIS as a document that
would be applicable to only ANRs.

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Because this GEIS was initially developed using a technology-neutral, performance-based
approach, its analyses can be used by any reactor. In SRM SECY-21-0098, dated April 17,
2024, the Commission directed the NRC staff to change the limited applicability of the GEIS
from solely “advanced nuclear reactors” to any new nuclear reactor licensing application,
provided the application meets the values and the assumptions of the plant parameter
envelopes and the site parameter envelopes used to develop the GEIS.

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1.1

Purpose and Need for this GEIS

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The purpose and need for this GEIS is to present impact analyses for the environmental issues
common to many new nuclear reactors 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. This GEIS is intended to improve the
efficiency of licensing new nuclear reactors by (1) identifying the types of potential
environmental impacts1 of constructing and operating a nuclear reactor, (2) assessing impacts
that are expected to be generic (the same or similar) for many new nuclear reactors, and
(3) defining the environmental issues that will need to be addressed in project-specific
supplemental EISs (SEISs) addressing specific projects.

1.2

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After completing the exploratory process, the NRC established an interdisciplinary team of
environmental subject matter experts (SMEs) to develop this GEIS. The team comprised
experts from the NRC staff and from contractors, including Pacific Northwest National
Laboratory, possessing extensive experience in evaluating the environmental impacts of new
reactors. The SMEs included individuals who have expertise in nuclear technology, radiation
protection, land use, aquatic and terrestrial ecology, hydrology and water use, socioeconomics,
environmental justice, meteorology and air quality, and human health. A complete list of SMEs,
their credentials, and their roles in preparing this GEIS is provided in Appendix A of this GEIS.

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On April 30, 2020, the NRC issued a Federal Register notice informing the public of its intent to
develop an ANR GEIS and to conduct a scoping process to gather the information necessary to
prepare an ANR GEIS for small-scale ANRs (85 FR 24040-TN6458). The NRC held a webinar
on May 28, 2020, to receive comments from the public on the scope of this GEIS (NRC 2020TN6459).

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The Federal Register notice stated that the NRC intended to develop a GEIS for ANRs that
have a small generating output and correspondingly small environmental footprint in order to
streamline the environmental review process for future small-scale ANR environmental reviews
(85 FR 24040-TN6458). At the time of scoping, the NRC staff considered a “small-scale” ANR to
be one that has the potential to generate up to approximately 30 megawatts thermal (MWt) per
unit and has a correspondingly small environmental footprint. The staff indicated that the actual
bounding thermal power level and environmental footprint used in this GEIS were topics to be
determined during the scoping process.

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The NRC received a number of comments about the scope of this GEIS during the May 28,
2020, webinar and throughout the scoping comment period. A summary of the scoping
comments was issued on September 25, 2020 (NRC 2020-TN6593). A number of commenters
questioned the utility of a GEIS for ANRs, given that the NRC did not know the type of reactor or
the site where the reactor would be located. Others agreed with the technology-neutral
approach but recommended a performance-based approach without limiting this GEIS to smallscale reactors. Based on the comments received during scoping, the NRC determined to use a
technology-neutral, performance-based approach with specified values and assumptions.
“Performance” reflects the ability of an applicant to design a nuclear reactor that minimizes

NEPA Process

This GEIS documents the potential impacts of construction, operation and decommissioning of new
nuclear reactors and henceforth when discussing impacts, they are potential impacts.

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environmental impacts while still meeting the reactor’s objectives. The approach outlined above
constitutes a technology-neutral, performance-based approach whereby the efficiencies gained
through use of this GEIS increase as the potential for environmental impacts decreases.

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The Commission, in SRM SECY-21-0098, dated April 17, 2024, directed the NRC staff to
change the limited applicability of the GEIS initially developed from solely “advanced nuclear
reactors” to any new nuclear reactor licensing application, provided the application meets the
values and the assumptions of the plant parameter envelopes and the site parameter envelopes
used to develop the GEIS. Therefore, this document is referred to as the new reactor (NR) GEIS
throughout the content.

1.3

Analytical Approach Used in this GEIS

1.3.1

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This section discusses the methodology the NRC staff used to develop this GEIS. This GEIS
evaluates the impacts of building, operating, and decommissioning a nuclear reactor sited within
the United States and its territories that is bounded by the values and assumptions in
Appendix G and the analyses in this GEIS. In addition, this GEIS considered fuel cycle impacts
and the impacts from continued storage of spent fuel after operations. The term building, as
used in this GEIS, includes the full range of preconstruction (building activities not within the
NRC’s regulatory authority), and construction and installation activities (building activities within
the NRC’s regulatory authority). The term construction worker includes any worker engaged in
building activities and the term construction equipment includes any equipment used for building
activities. For the purposes of this GEIS, the staff assumed that the U.S. Army Corps of
Engineers (USACE) would be a cooperating agency, in accordance with the Memorandum of
Understanding between the two agencies (USACE and NRC 2008-TN637). Based on this
assumption, preconstruction activities are addressed in Chapter 3 along with the impacts of
NRC-authorized construction.

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Because new nuclear 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 Title 10 of the Code of Federal Regulations Part 100 (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 site footprint size, 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.

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In addition, the staff developed a set of site-related parameters termed the site parameter
envelope (SPE). Examples of parameters include 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 GEIS 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.

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The PPE and SPE are presented in Appendix G. The PPE and SPE values and assumptions
were developed by the interdisciplinary team of SMEs assigned to prepare this GEIS. The
SMEs developed the values and assumptions based on one or more of the following:

Methodology

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• regulatory limits and permitting requirements relevant to the resource as established by
Federal, State, or local agencies;

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• relevant information obtained from other NRC GEISs, including the License Renewal GEIS
(NRC 2024-TN10161) and the Continued Storage GEIS (NRC 2014-TN4117);

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• empirical knowledge gained from conducting evaluations and analyses for past new reactor
environmental impact statements (EISs);

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• values and assumptions derived from other documents applying a PPE/SPE approach (such
as the National Reactor Innovation Center [NRIC] PPE Report; NRIC 2021-TN6940); and

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• subject matter expertise and/or development of calculations and formulas based upon
education and experience with the resource.

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The SMEs strove to ensure that the PPE and SPE were set broadly enough to make this GEIS
a useful licensing tool, while still ensuring that enough project-specific analysis would be
completed upon receipt of an application to document significant environmental impacts for the
public and decision-makers.

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The NRC staff presented preliminary tables outlining the PPE and SPE at the March 28, 2020,
scoping meeting. The PPE and SPE presented in Appendix G reflect the staff’s consideration of
comments received during the scoping process and subsequent research conducted by the
SMEs to prepare the draft GEIS.

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The SMEs started their analysis by identifying 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 interdisciplinary team of SMEs that
could potentially result from construction or operation of a nuclear reactor. The SMEs identified
122 specific issues. For each issue, the SMEs then determined whether it would be possible to
identify values and assumptions in the PPE and SPE that could effectively bound a meaningful
generic analysis and provided the basis for each value and assumption. The SMEs 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 this GEIS, the values and
assumptions were set such that the SMEs 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.

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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
(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 require site- or project-specific analysis in an
NRC EIS.

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The SMEs drew conclusions about each analysis using one of the three significance levels that
the NRC staff typically uses in EISs for new reactors, including the following:

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• SMALL – Environmental effects that are not detectable or are so minor that they will neither
destabilize nor noticeably alter any important attribute of the resource. For the purposes of

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assessing radiological impacts, the Commission has concluded that those impacts that do
not exceed permissible levels in the Commission’s regulations are considered SMALL.

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• MODERATE – Environmental effects are sufficient to alter noticeably, but not to destabilize,
important attributes of the resource.

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• LARGE – Environmental effects are clearly noticeable and are sufficient to destabilize
important attributes of the resource.

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These significance levels follow the definitions presented in the footnotes in Table B-1 in
Appendix B of Subpart A of 10 CFR Part 51 (TN250). These are the same environmental
significance levels and definitions used in the License Renewal GEIS (NRC 2024-TN10161) and
in recent EISs prepared by the NRC staff for combined licenses and early site permits for new
light-water reactors (LWRs). The discussion of each Category 1 environmental impact issue in
this GEIS includes an explanation of how the significance category of SMALL was determined.
For issues for which the probability of occurrence is a key consideration (i.e., postulated
accidents), the probability of occurrence has been factored into the determination of
significance. Possible mitigation measures that could be used to avoid, minimize, rectify,
reduce, eliminate, or compensate for adverse impacts are discussed where appropriate.

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• The SMEs assigned each issue to one of the two categories depending on the potential
utility of the generic analysis to applicants preparing specific new nuclear reactor licensing
applications and to the NRC staff when completing environmental reviews of those
applications. In summary, the categories are as follows:

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In addition, as discussed in Section 1.3.3.3, there are two issues that are designated as N/A
(i.e., impacts are Uncertain), which are neither Category 1 nor 2.

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Category 1 issues include one or more PPE/SPE parameters with associated values and
assumptions; these values and assumptions are set to define a SMALL impact. This GEIS
provides generic analyses for these Category 1 environmental issues, organized under the
16 environmental resources described in Chapter 3 of this GEIS.

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An applicant addressing a Category 1 issue in its environmental report (ER) may refer to the
generic analysis in this GEIS for that issue without further analysis, provided that it
demonstrates that the relevant values and assumptions of the PPE and SPE used in the
resource analysis are met and there is no new and significant information that would require
project-specific analysis. The applicant will have to document how the values and assumptions
are met, unless this is made clear in other information provided in the application package. The
extent of the information necessary to demonstrate that a value or assumption is met will vary.
In some cases, the demonstration may only require showing that the project falls within a
parameter value or assumption (e.g., building height). But in other cases, analysis may be
required to demonstrate that a value or assumption has been met (e.g., building- or operationsrelated noise levels).

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If the relevant values and assumptions for a Category 1 issue are not met, the applicant would
have to supply the requisite information necessary for the staff to perform a project-specific
analysis. One place for guidance for applicants providing information to the staff in an ER is
available in the latest version of Regulatory Guide (RG) 4.2 2 (NRC 2024-TN7081). The applicant
may, however, be able to incorporate by reference all or part of the generic analysis provided in
this GEIS and focus on providing the additional project-specific information needed. Applicants
addressing Category 2 issues in an ER would have to provide all the information typically
needed by the staff to perform a project-specific analysis and may rely on guidance available in
RG 4.2 (NRC 2024-TN7081). The staff expects that applicants may be able to rely on the
generic conclusions for certain Category 1 issues, but not all Category 1 issues.

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When addressing Category 1 issues in SEISs, the NRC staff may likewise refer to the generic
analysis in this GEIS for that issue without further analysis, provided that the relevant values
and assumptions in the PPE and SPE are met and there is no new and significant information
that changes the conclusions in this GEIS. Staff may also have to briefly document how the
values and assumptions are met. If the relevant values and assumptions are not met, staff
would have to complete a project-specific analysis in accordance with the latest version of the
Environmental Standard Review Plan or related guidance (such as any relevant Interim Staff
Guidance). Staff may however be able to streamline the effort by incorporating all or a portion of
the generic analysis in this GEIS and expanding it to account for project-specific information.

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It is possible that applicants for certain new nuclear reactors carefully designed to minimize
environmental impacts may be able to demonstrate that their projects fall within all or most of
the values and assumptions and may be able to reference generic analyses in this GEIS for all
or most of the Category 1 environmental issues. In such a case, the NRC staff’s SEIS would
likely be shorter than an EIS has been in the past for a typical new reactor application. Also, as
has always been the case, if the design of a project is such that an environmental issue (or
group of environmental issues) is not applicable, then the applicant need not analyze the
issue(s). For example, if the nuclear reactor design does not use cooling water then the impact
issues associated with the use of cooling water do not need to be analyzed. However, the
applicant must briefly describe its basis for concluding that the issue(s) is/are not applicable.

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The NRC cannot rely on this GEIS alone to analyze the environmental impacts of construction
or operation of any nuclear reactors. For example, the staff would still have to conduct the
consultations required by Section 106 of the National Historic Preservation Act (54 U.S.C.
§§ 300101 et seq.; TN4157) and Section 7 of the ESA (16 U.S.C. §§ 1531 et seq.; TN1010) and
include the documentation in the SEIS for each application using this GEIS. Therefore, these
consultations will not be part of this GEIS. The NRC staff will still have to complete other projectspecific analyses upon receiving a new nuclear reactor application.

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The NRC staff has evaluated fuel cycle impacts for LWRs, as documented in 10 CFR 51.51
(10 CFR Part 51-TN250), Table S-3, Table of Uranium Fuel Cycle Environmental Data.
However, in accordance with 10 CFR 51.51, only an ER for LWRs can include Table S-3. For
reactors other than LWRs, the application must contain the basis for evaluating the contribution
of the environmental effects of fuel cycle activities for the reactor (10 CFR 51.50(b)(3) and
10 CFR 51.50(c)). Section 3.14 of this NR GEIS evaluated the fuel cycle impacts for nuclear
reactor fuel and determined that data from Table S-3 could bound the impacts of the fuel cycle
for certain advanced non-LWRs. An applicant for an advanced non-LWR license could meet the
2

Unless stated otherwise, references to RG 4.2 in this document refer to DG-4032 (NRC 2022-TN7081),
the draft revision to RG 4.2, which is being published at the same time as this draft GEIS.

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requirements of 10 CFR 51.50(b)(3) and 10 CFR 51.50(c) by demonstrating that their fuel falls
within the fuel cycle analysis in this GEIS. If the fuel cycle or parts of the fuel cycle do not fall
within the analysis in this GEIS, then the applicant would need to provide the analysis of the
parts of the fuel cycle that are not bounded.

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This GEIS incorporates by reference NUREG-2157, Generic Environmental Impact Statement
for Continued Storage of Spent Nuclear Fuel (NRC 2014-TN4117), in which the NRC evaluated
the environmental impacts of the continued storage of spent nuclear fuel beyond the licensed
life for the operation of LWRs. In 10 CFR 51.23 (TN250), “Environmental impacts of continued
storage of spent nuclear fuel beyond the licensed life for operation of a reactor,” the NRC
specifies that NUREG-2157 is deemed to be incorporated into the EIS for a new reactor.
However, NUREG-2157 did not evaluate the storage of spent nuclear fuel from non-LWRs. The
staff expects that many new nuclear reactors will not be LWRs. Section 3.14.2.6 of this
NR GEIS therefore evaluates the applicability of NUREG-2157 and determines that the findings
were applicable to non-LWR fuel, provided that the non-LWR fuel is stored in a manner that
meets the regulatory requirements for spent fuel storage cask approval and fabrication in
accordance with 10 CFR Part 72 (TN4884), Subpart L – “Approval of Spent Fuel Storage
Casks,” as was the LWR spent fuel evaluated in NUREG-2157 (NRC 2014-TN4117).

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The NRC has generically evaluated the environmental impacts of the transportation of fuel and
waste in 10 CFR 51.52 (TN250), “Environmental effects of transportation of fuel and waste –
Table S4,” Table S-4, Environmental Impact of Transportation of Fuel and Waste to and from
One Light Water Cooled Nuclear Power Reactor, for LWR fuel that meets certain entry
conditions specified in 10 CFR 51.52(a). The staff evaluated the impacts of transportation of
non-LWR fuel and waste in Section 3.15 of this GEIS and determined that the shipment of
unirradiated and irradiated non-LWR fuel and radioactive waste would be a Category 1 issue.
The applicant can rely on the generic analysis as long as the PPE values and assumptions are
met.

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This GEIS incorporates by reference NUREG-0586, Supplement 1 (NRC 2002-TN665), in which
the NRC evaluated the environmental impacts of the decommissioning of nuclear power
reactors as residual radioactivity at the site is reduced to levels that allow for termination of the
NRC license. The NRC staff’s evaluation of the environmental impacts of decommissioning
presented in NUREG-0586, Supplement 1, considered environmental issues for LWRs and
three permanently shutdown facilities that included a fast breeder reactor and two
high-temperature gas-cooled reactors (NRC 2002-TN665). NUREG-0586, Supplement 1,
identified whether the environmental issues were considered generic to all decommissioning
sites or project-specific. While most issues were considered generic to all decommissioning
sites, two issues were determined to require a project-specific review and four issues were
considered to be conditionally project-specific. Therefore, in Section 3.16.2 of this GEIS, the
NRC staff evaluated the applicability of NUREG-0586, Supplement 1, and determined that the
findings for the issues considered generic to all decommissioning sites are expected to be
applicable to any new nuclear reactor, provided that the impacts from decommissioning can be
shown to be within the bounds described in the Decommissioning GEIS, and that regulatory
requirements for decommissioning in 10 CFR 50.82 (TN249) or 10 CFR 52.110 (TN251) are
met. Additional analysis would be required for the identified project-specific issues.

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In summary, the general analytical approach used by the NRC staff in this GEIS to evaluate
environmental impacts was to (1) describe each environmental issue relevant to each of the 16
environmental resources considered; (2) categorize each issue as Category 1 or Category 2;

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(3) identify for each Category 1 issue the relevant values and assumptions in the PPE and SPE;
and (4) assess the significance of the environmental impact on the Category 1 issue.

1.3.2

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The NRC staff drew information from a broad range of sources while developing this GEIS,
including the following more prominent written sources:

Primary Documents Used to Develop this GEIS

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• Results of Exploratory Process for Developing a Generic Environmental Impact Statement
for the Construction and Operation of Advanced Nuclear Reactors (SECY-20-0020,
NRC 2020-TN6493)

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• Staff Requirements – SECY-20-0020 – Results of Exploratory Process for Developing a
Generic Environmental Impact Statement for the Construction and Operation of Advanced
Nuclear Reactors (SRM-SECY-20-0020, NRC 2020-TN6492)

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• Staff Requirements – SECY-21-0098 – Proposed Rule: Advanced Nuclear Reactor Generic
Environmental Impact Statement (SRM SECY-21-0098, NRC 2021-TN10127)

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• Staff Requirements – SECY-23-0001 – Options for Licensing and Regulating Fusion Energy
Systems (SRM SECY-23-0001, NRC 2023-TN10128)

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• Standard Review Plans for Environmental Reviews for Nuclear Power Plants
(NUREG-1555, NRC 2000-TN614)

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• Preparation of Environmental Reports for Nuclear Power Stations (RG 4.2, NRC 2018TN6006)

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• Generic Environmental Impact Statement for License Renewal of Nuclear Plants
(NUREG-1437, NRC 2024-TN10161)

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• Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities

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• Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel:
Final Report, Volumes 1 and 2 (NUREG-2157, NRC 2014-TN4117)

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• Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities:
Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (NUREG-0586,
Supplement 1, NRC 2002-TN665)

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• Environmental Considerations Associated with Micro-Reactors (COL-ISG-029, NRC 2019TN6523)

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• Final Environmental Assessment for the Use of Department of Energy-Owned High-Assay
Low-Enriched Uranium Stored at Idaho National Laboratory (DOE/EA-2087; DOE 2019TN6757)

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• Advanced Nuclear Reactor Plant Parameter Envelope and Guidance (NRIC-21-ENG-0001;
PNNL-30992, NRIC 2021-TN6940)

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• Advances in Small Modular Reactor Technology Developments; A Supplement to IAEA
Advanced Reactors Information System (ARIS), 2020 Edition (IAEA 2020-TN6953)

• Manifest Information Management System (DOE 2024-TN10120).

(NUREG-1910, NRC 2009-TN2559)

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1.3.3

Issue Categories

1.3.3.1

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This GEIS identifies 100 environmental issues as Category 1 issues. Chapter 3 of this GEIS
provides generic analyses for each Category 1 issue and indicates the relevant values and
assumptions in the PPE and SPE underlying the analyses. Applicants and NRC staff may rely
on the generic analysis for each Category 1 issue provided that the relevant values and
assumptions are met and there is no new and significant information that changes the
conclusions in this GEIS.

Category 1 Issues – Generic Analysis

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These issues and a list of the sections where they are discussed in this GEIS are listed in
Table 1-1 (in Section 1.3.3.3).

1.3.3.2

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This GEIS identifies 20 environmental issues as Category 2 issues. These issues cannot be
evaluated generically and must be evaluated in the ER and SEIS using project-specific
information. For example, the ESA requires every Federal agency to document its consideration
of the impacts of its actions on threatened and endangered species and critical habitats. This
ESA Section 7 consultation requirement is required in addition to NEPA; however, the impacts
on threatened and endangered species and critical habitat are considered in the NEPA
documents.

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These issues and a list of the sections where they are discussed in this GEIS are listed in
Table 1-1.

1.3.3.2.1 Resource-Specific Category 2 Issues

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Category 2 issues specific to a given environmental resource are described in the applicable
section of Chapter 3.

1.3.3.2.2 Category 2 Issues Applying Across Resources

Certain Category 2 issues apply across all resources and are summarized below.

Climate Change

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Climate change is a subject of national and international interest that causes changes to the
affected environment. Commission Order CLI-09-21 (NRC 2009-TN6406) provides the current
direction to the NRC staff to include the consideration of the impacts of the emissions of carbon
dioxide and other greenhouse gases in its environmental reviews for major licensing actions.
Climate change is an environmental trend that could result in changes to the affected
environment independent of the new nuclear reactor project. Climate-related changes include
rising temperatures and sea levels; increased frequency and intensity of extreme weather (e.g.,
heavy downpours, floods, and droughts); earlier snowmelts and associated frequent wildfires;
and reduced snow cover, glaciers, permafrost, and sea ice. Greenhouse gases are transparent
to incoming short-wave radiation from the sun but opaque to outgoing long-wave (infrared)
radiation from the Earth’s surface. The net effect over time is a trapping of absorbed radiation
and a tendency to warm the Earth’s atmosphere, which together constitute the “greenhouse
effect” (GCRP 2014-TN3472, USGCRP 2023-TN9762).

Category 2 Issues – Project-Specific Analysis

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The NRC staff has considered the impacts of climate change in its recent new reactor EISs.
Climate change can lead to changes in the affected environment around a new reactor project,
potentially influencing the level of impacts on resources affected by the project. However, the
effects of climate change are location-specific and cannot, therefore, be evaluated generically.
For example, while climate change may cause many areas to receive less average annual
precipitation, other areas may see an increase in average annual precipitation. Therefore,
applicants and staff will address the effects of climate change in the environmental documents
for new nuclear reactor licensing. For additional information, see RG 4.2 (NRC 2024-TN7081)
and Interim Staff Guidance (ISG), COL/ESP-ISG-026 (NRC 2014-TN3767).

Cumulative Effects

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Cumulative effects are the effects on the environment that result from the incremental effects of
the proposed action when added to the effects of other past, present, and reasonably
foreseeable actions, regardless of which agency (Federal or non-Federal) or person undertakes
such other actions. Evaluating cumulative effects without knowing specific site locations or the
time frame for evaluating reasonably foreseeable actions is not possible generically. The
cumulative effects of building and operating a nuclear reactor must be considered on a
project-specific basis. Effects would depend on regional resource characteristics, the
resource-specific impacts of the proposed project, and the cumulative significance of other
factors affecting the resource. This is a Category 2 issue.

1.3.3.2.3 Non-Resource Related Category 2 Issues

21
22
23
24
25
26
27
28
29
30
31

This GEIS addresses the environmental impact issues associated with building and operating a
nuclear reactor. However, the ER and the staff’s SEIS must also include other information, as
required by the regulations and discussed in regulatory guidance. These are not resourcespecific issues. Rather, they are project-specific issues, not tied to any specific environmental
resource, that are necessary to support the NRC staff’s completion of its environmental review
in accordance with NEPA. These issues cannot be evaluated generically and must be
addressed in the ER and SEIS using project-specific information. Because of their unique
nature, some of these issues are discussed further below, and are summarized in Table 4-1 (in
Chapter 4). This list is not all-inclusive. NRC regulations at 10 CFR Part 51 (TN250) and
guidance such as RG 4.2 (NRC 2024-TN7081) describe information not included in this list that
must be included as part of an application.

Purpose and Need

33
34
35
36
37
38
39
40

The applicant must describe in its ER the purpose and need for its proposed action, i.e., the
reasons for developing the project (10 CFR 51.45(b); TN250). The NRC staff will use this
information to inform its development of the NRC’s purpose and need in the SEIS. Properly
defining the purpose and need is a critical step in the development of an environmental
document for the purposes of meeting NEPA requirements because it establishes the need for
the action and the range of reasonable alternatives that must be considered. For additional
information, see RG 4.2 (NRC 2024-TN7081, ISG COL/ESP-ISG-026 (NRC 2014-TN3767), and
COL-ISG-029 (NRC 2019-TN6523).

Need for Power

42
43

The Atomic Energy Act requires the social and environmental consequences of the civilian use
of nuclear materials be weighed against the benefits that their use would provide. Historically,

1-10

1
2
3
4
5
6
7
8

the primary benefit of nuclear power generation projects has been to provide electrical power to
the grid. Therefore, the NRC staff has evaluated the need for power in its new reactor EISs. Any
new nuclear reactor that uses this GEIS may also provide power to the grid, and if so, may
require the same type of need for power evaluation in both the ER and SEIS. However, some
nuclear reactors may be built for other purposes (e.g., to generate process heat, to desalinate
water, or as a research and demonstration project). In such cases, the applicant will need to
present, and the NRC staff will have to evaluate, the need for the project (10 CFR 51.45(b);
TN250).

Alternatives

10
11
12
13
14
15
16
17

The applicant’s ER must address alternatives to the proposed action (10 CFR 51.45(b)(3) and
(c); TN250). Identification and evaluation of alternatives for any proposed action are inherently
project-specific. The NRC staff is unable to generically evaluate alternatives universally
applicable to licensing of new nuclear reactors. This GEIS therefore does not consider any
alternatives to the action of constructing and operating a nuclear reactor. Identification of a
range of reasonable alternatives3 requires consideration of information about a specific project
and site. The staff will have to individually consider the range of reasonable alternatives that
meet the purpose and need behind each incoming new nuclear reactor licensing application.

18
19
20
21
22
23
24

Most new reactor EISs prepared by the NRC staff have evaluated alternatives with respect to
the proposed reactor site (site alternatives), with respect to fuel used to generate the requisite
power (energy alternatives), and with respect to cooling system use (system design
alternatives). Each of these broad types of alternatives is briefly discussed in the sections
below. The staff expects that the range of reasonable alternatives will differ for each incoming
new nuclear reactor licensing application and may include alternatives from one or more of
these groupings of possible alternatives. Other types of alternatives might also be possible.

Site Alternatives

26
27
28
29
30
31
32
33
34
35
36
37
38

New reactor EISs prepared by NRC staff have evaluated in detail situating the proposed reactor
at three or four alternative sites as well as the proposed site (unless siting has been previously
addressed, as in the case of a combined license referencing an early site permit). For any site
to be a reasonable alternative, it must meet all of the NRC siting criteria established in 10 CFR
Part 100 (TN282). Applicants typically consider many other factors as well when determining
whether sites are reasonable alternatives—factors such as proximity to customers, proximity to
existing transmission lines, availability of water sources, land ownership, avoidance of sensitive
features such as wetlands and historic sites, accessibility to workers, and considerations of local
residents and government officials. Applicants often favor sites on or adjacent to existing
nuclear plant sites or sites containing other energy generation facilities. The advantages of such
sites include the availability of existing transmission lines, pipelines, highways, and other
facilities that do not have to be newly built, thereby reducing construction costs and disturbance
to non-industrial landscapes and environmentally sensitive lands.

Changes to the NEPA statute (42 U.S.C. § 4321 et seq.) from the Fiscal Responsibility Act of 2023
(Public Law No. 118-5, 137 Stat. 10) included adding a new Section 102(2)(F) directing agencies to
“…study, develop, and describe technically and economically feasible alternatives.” The Council on
Environmental Quality defines “reasonable alternatives” as meaning a “reasonable range of alternatives
that are technically and economically feasible, and meet the purpose and need for the proposed action”
(40 CFR 1508.1(hh)).

1-11

1
2
3
4

Applicants commonly follow systematic approaches to narrowing a field of potential sites such
as that developed by the Electric Power Research Institute (EPRI 2015-TN5285). However, use
of any specific siting guidance is not mandatory. The NRC offers additional guidance in RG 4.7
(NRC 2014-TN3550).

5
6
7

The geographical area that must be considered for site alternatives will be determined based on
the purpose and need for the proposed action. ISG COL/ESP-027 (NRC 2014-TN3774)
contains some insights regarding this aspect in its discussion of Chapter 9.

8
9
10
11
12
13
14
15

According to ISG-027, an applicant may request construction at a specific location to meet its
purpose and need for a light-water small modular reactor (SMR) facility (NRC 2014-TN3774).
For example, an applicant may propose to use excess heat for industrial processes or station
heating. A proposed SMR may be used to provide a secure energy source for military,
government, or critical industrial facilities. In these cases, the applicant must still submit and the
staff must review alternative sites. However, the region of interest used for the site selection
process may be much smaller than is typical for large LWRs (e.g., within the confines of a
military installation).

16
17
18
19

Although the ISG was written specifically for SMRs, the fundamental concept is informative for
most other new nuclear reactors as well. The range of alternatives that must be considered is a
direct product of the purpose and need for the proposed action. The proposed and alternative
sites can be adjacent to each other.

20
21
22
23

This GEIS can be used for both the proposed and alternative sites for the evaluation of resource
impacts. However, the application 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

25
26
27
28
29
30

A reasonable alternative must meet the purpose and need for the project. For example, new
reactor EISs recently have evaluated alternatives that could meet the purpose and need for the
project to supply baseload power. The EISs have evaluated alternatives such as coal, natural
gas, and mixtures of natural gas and renewable energy sources that could supply baseload
power. Energy sources such as wind and solar by themselves were not considered reasonable
alternatives because they could not supply baseload power.

31
32
33
34
35
36
37
38
39

The range of alternative energy sources constituting reasonable alternatives for each proposed
new nuclear reactor project may differ. For example, if the purpose and need statement was “to
demonstrate a specific type of advanced reactor technology to supply power,” then coal, natural
gas, wind, or solar would not be reasonable alternatives because they do not demonstrate the
specific type of nuclear reactor technology and therefore the EIS would not evaluate them.
Other potential purposes of new reactors include desalinating water, providing process heat, or
aiding States in meeting carbon emission goals. Because the purpose and need for each project
is likely to be different, applicants and the NRC staff would have to individually identify
reasonable alternatives suited to each specific application.

System Design Alternatives

41
42

Because operation of water-based cooling systems to discharge waste heat from large nuclear
reactors has the potential to significantly affect the water bodies from which water is taken, and

1-12

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

into which it is discharged, new reactor EISs recently prepared by NRC staff have evaluated
alternative system designs that use different cooling processes. Possible cooling systems
considered have included (1) once-through cooling, in which water is withdrawn from a source
such as a river or lake and run through the system once to absorb waste heat before being
returned to the source; (2) recirculating cooling-water systems, in which water is withdrawn and
recirculated through cooling towers multiple times (cycles of concentration) before being
discharged; (3) air cooling that does not involve water; and (4) use of multiple cooling
approaches. Different types of cooling towers are also possible, such as natural draft cooling
towers comprising tall hyperbolic structures that direct air upward on a pressure gradient to cool
water, or lower mechanical draft cooling towers that use electrically driven fans to cool water.
Consideration of system design alternatives involving cooling systems may not be appropriate
for nuclear reactors designed for air cooling or for which smaller volumes of cooling water may
be used. If the design of the project does not use cooling water, then an evaluation of alternative
cooling systems is not required. Because of the wide range of possible new nuclear reactor
technologies, the NRC staff is not able to anticipate all possible alternative design approaches
that might be reasonable.

1.3.3.3

18
19
20
21
22
23
24
25
26

The GEIS identifies the impacts of two issues as Uncertain, and therefore the determination of
Category 1 or Category 2 is not applicable (N/A). These issues relate to exposure to
electromagnetic fields (EMFs). Studies of 60 hertz (Hz) EMFs have not uncovered consistent
evidence linking harmful effects with field exposures. Because the state of the science is
currently inadequate, no generic conclusion on human health impacts is possible. If, in the
future, the Commission finds that a general agreement has been reached by appropriate
Federal health agencies that there are adverse health effects from EMFs, the Commission will
require applicants to submit plant-specific reviews of these health effects as part of their
application. Until such time, applicants are not required to submit information on this issue.

Uncertain Issues

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement
Issue

Section

Category

3.1.2.1.1
3.1.2.1.2
3.1.2.1.3
3.1.2.1.4

1
1
1
1

3.1.2.2.1
3.1.2.2.2

1
1

3.2.2.1.1
3.2.2.1.2

1
1

3.2.2.2.1

Land Use
Construction
Onsite Land Use
Offsite Land Use
Impacts to Prime and Unique Farmland
Coastal Zone and Compliance with the Coastal Zone Management Act
Operation
Onsite Land Use
Offsite Land Use
Visual
Construction
Visual Impacts in Site and Vicinity
Visual Impacts from Transmission Lines
Operation
Visual Impacts During Operations

28
29

1-13

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement (Continued)
Issue
Air Quality
Construction
Emissions of Criteria Pollutants and Dust During Construction
Greenhouse Gas Emissions During Construction
Operation
Emissions of Criteria and Hazardous Air Pollutants during Operation
Greenhouse Gas Emissions During Operation
Cooling-System Emissions
Emissions of Ozone and oxides of nitrogen (NOx) during Transmission
Line Operation
Water Resource
Construction
Surface Water Use Conflicts during Construction
Groundwater Use Conflicts due to Excavation Dewatering
Groundwater Use Conflicts due to Construction-Related Groundwater
Withdrawals
Water Quality Degradation due to Construction-Related Discharges
Water Quality Degradation due to Inadvertent Spills during
Construction
Water Quality Degradation due to Groundwater Withdrawal
Water Quality Degradation due to Offshore or In-Water Construction
Activities
Water Use Conflict Due to Plant Municipal Water Demand
Degradation of Water Quality from Plant Effluent Discharges to
Municipal Systems
Operation
Surface Water Use Conflicts during Operation due to Water Withdrawal
from Flowing Water Bodies
Surface Water Use Conflicts during Operation due to Water Withdrawal
from Non-flowing Water Bodies
Groundwater Use Conflicts Due to Building Foundation Dewatering
Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant
Uses
Surface Water Quality Degradation Due to Physical Effects from
Operation of Intake and Discharge Structures
Surface Water Quality Degradation Due to Changes in Salinity
Gradients Resulting from Withdrawals
Surface Water Quality Degradation Due to Chemical and Thermal
Discharges
Groundwater Quality Degradation Due to Plant Discharges
Water Quality Degradation due to Inadvertent Spills and Leaks during
Operation
Water Quality Degradation due to Groundwater Withdrawals
Water Use Conflict from Plant Municipal Water Demand

1-14

Section

Category

3.3.2.1.1
3.3.2.1.2

1
1

3.3.2.2.1
3.3.2.2.2
3.3.2.2.3
3.3.2.2.4

1
1
1
1

3.4.2.1.1
3.4.2.1.2
3.4.2.1.3

1
1
1

3.4.2.1.4
3.4.2.1.5

1
1

3.4.2.1.6
3.4.2.1.7

1
1

3.4.2.1.8
3.4.2.1.9

1
1

3.4.2.2.1

3.4.2.2.3
3.4.2.2.4

1
1

3.4.2.2.5

3.4.2.2.6

3.4.2.2.7

3.4.2.2.8
3.4.2.2.9

1
1

3.4.2.2.10
3.4.2.2.11

1
1

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement (Continued)
Issue
Degradation of Water Quality from Plant Effluent Discharges to
Municipal Systems
Terrestrial Ecology
Construction
Permanent and Temporary Loss, Conversion, Fragmentation, and
Degradation of Habitats
Permanent and Temporary Loss and Degradation of Wetlands
Effects of Building Noise on Wildlife
Effects of Vehicular Collisions on Wildlife
Bird Collisions and Injury from Structures and Transmission Lines
Important Species and Habitats – Resources Regulated under the
Endangered Species Act of 1973
Important Species and Habitats – Other Important Species and
Habitats
Operation
Permanent and Temporary Loss or Disturbance of Habitats
Effects of Operational Noise on Wildlife
Effects of Vehicular Collisions on Wildlife
Exposure of Terrestrial Organisms to Radionuclides
Cooling-Tower Operational Impacts on Vegetation
Bird Collisions and Injury from Structures and Transmission Lines
Bird Electrocutions from Transmission Lines
Water Use Conflicts with Terrestrial Resources
Effects of Transmission Line ROW Management on Terrestrial
Resources
Effects of Electromagnetic Fields on Flora and Fauna
Important Species and Habitats – Resources Regulated under the ESA
of 1973
Important Species and Habitats – Other Important Species and
Habitats
Aquatic Ecology
Construction
Runoff and Sedimentation from Construction Areas
Dredging and Filling Aquatic Habitats to Build Intake and Discharge
Structures
Building Transmission Lines, Pipelines, and Access Roads Across
Surface Waterbodies
Important Species and Habitats – Resources Regulated under the ESA
and Magnuson-Stevens Fishery Conservation and Management Act
Important species and habitats – Other Important Species and Habitats
Operation
Stormwater Runoff
Exposure of Aquatic Organisms to Radionuclides
Effects of Refurbishment on Aquatic Biota

1-15

Section
3.4.2.2.12

Category
1

3.5.2.1.1

3.5.2.1.2
3.5.2.1.3
3.5.2.1.4
3.5.2.1.5
3.5.2.1.6

1
1
1
1
2

3.5.2.1.6

3.5.2.2.1
3.5.2.2.2
3.5.2.2.2
3.5.2.2.3
3.5.2.2.4
3.5.2.2.5
3.5.2.2.6
3.5.2.2.7
3.5.2.2.8

1
1
1
1
1
1
1
1
1

3.5.2.2.9
3.5.2.2.10

1
2

3.5.2.2.10

3.6.2.1.1
3.6.2.1.2

1
1

3.6.2.1.3

3.6.2.1.4

3.6.2.2.1
3.6.2.2.2
3.6.2.2.3

1
1
1

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement (Continued)
Issue
Effects of Maintenance Dredging on Aquatic Biota
Impacts of Transmission Line ROW Management on Aquatic
Resources
Impingement and Entrainment of Aquatic Organisms
Thermal Impacts on Aquatic Biota
Other Effects of Cooling-Water Discharges on Aquatic Biota
Water Use Conflicts with Aquatic Resources
Important Species and Habitats – Resources Regulated under the ESA
and Magnuson-Stevens Act
Important species and habitats – Other Important Species and Habitats
Historic and Cultural Resources
Construction
Construction Impacts on Historic and Cultural Resources
Operation
Operation Impacts on Historic and Cultural Resources
Radiological Environment
Construction
Radiological Dose to Construction Workers
Operation
Occupational Doses to Workers
Maximally Exposed Individual Annual Doses
Total Population Annual Doses
Nonhuman Biota Doses
Nonradiological Environment
Construction
Building Impacts of Chemical, Biological, and Physical Nonradiological
Hazards
Building Impacts of EMFs
Operation
Operation Impacts of Chemical, Biological, and Physical
Nonradiological Hazards
Operation impacts of EMFs
Noise
Construction
Construction-Related Noise
Operation
Operation-Related Noise
Radiological Waste Management
Operation
Low-Level Radioactive Waste
Onsite Spent Nuclear Fuel and High-Level Waste Management
Mixed Waste

1-16

Section
3.6.2.2.4
3.6.2.2.5

Category
1
1

3.6.2.2.6
3.6.2.2.7
3.6.2.2.8
3.6.2.2.9
3.6.2.2.10

1
2
2
1
2

3.6.2.2.10

3.7.2

3.8.1.2.1

3.8.1.2.2
3.8.1.2.2
3.8.1.2.2
3.8.1.2.2

1
1
1
1

3.8.2.2.1

N/A

3.8.2.2.2

N/A

3.9.2.1

3.9.2.2

3.10.1.2.1
3.10.1.2.2
3.10.1.2.3

1
1
1

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement (Continued)
Issue
Nonradiological Waste Management
Construction
Construction Nonradiological Waste
Operation
Operation Nonradiological Waste

Section

Category

3.10.2.2.1

3.10.2.2.2

3.11.2.1
3.11.2.2
3.11.2.3
3.11.2.4
3.11.2.5

1
1
2
1
1

3.12.2.1.1
3.12.2.1.2
3.12.2.1.3
3.12.2.1.4

1
1
1
1

3.12.2.2.1
3.12.2.2.2
3.12.2.2.3
3.12.2.2.4

1
1
1
1

3.13.2.1

3.14.2.1
3.14.2.2
3.14.2.3
3.14.2.4
3.14.2.5
3.14.2.6

1
1
1
1
1
1

3.15.2.1
3.15.2.2
3.15.2.3

1
1
1

Postulated Accidents
Operation
Design Basis Accidents Involving Radiological Releases
Accidents Involving Releases of Hazardous Chemicals
Severe Accidents
Severe Accident Mitigation Design Alternatives
Acts of Terrorism
Socioeconomics
Construction
Community Services and Infrastructure
Transportation Systems and Traffic
Economic Impacts
Tax Revenue Impacts
Operation
Community Services and Infrastructure
Transportation Systems and Traffic
Economic Impacts
Tax Revenue Impacts
Environmental Justice
Construction
Construction Environmental Justice Impacts
Operation
Operation Environmental Justice Impacts
Fuel Cycle
Operation
Uranium Recovery
Uranium Conversion
Enrichment
Fuel Fabrication(a)
Reprocessing
Storage and Disposal of Radiological Wastes
Transportation of Fuel and Waste
Operation
Transportation of Unirradiated New Reactor Fuel
Transportation of Radioactive Waste from New Reactors
Transportation of Irradiated Fuel from New Reactors

1-17

Table 1-1 Issues Discussed in the Generic Environmental Impact Statement (Continued)
Issue
Decommissioning
Decommissioning Impacts (generically addressed issues in
NUREG-0586)
Decommissioning Impacts (site-specific and/or conditionally sitespecific issues in NUREG-0586)
Issues Applying Across All Resources
Climate Change
Cumulative Impacts
Non-Resource Related Issues
Purpose and Need
Need for Power
Site Alternatives
Energy Alternatives
System Design Alternatives

Section

Category

3.16.2

1.3.3.2.2
1.3.3.2.2

2
2

1.3.3.2.3
1.3.3.2.3
1.3.3.2.3
1.3.3.2.3
1.3.3.2.3

2
2
2
2
2

(a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the NRC staff’s generic
analysis.

1.4

Implementation of the Rule (10 CFR Part 51)

2
3
4
5
6
7
8
9
10

Applicants and the NRC staff will use this GEIS as a tool to increase the efficiency and
effectiveness of environmental reviews for constructing and operating new nuclear reactors,
while at the same time ensuring that NRC’s NEPA requirements are met. This GEIS presents
generic analyses of environmental impacts that the staff expects will be common to most new
nuclear reactors meeting a set of design conditions (termed the PPE) built on a hypothetical site
meeting a set of site conditions (termed the SPE) (Appendix G). Applicants will be able to
streamline ERs by referring to the generic analyses in this GEIS codified in 10 CFR Part 51
(TN250) whenever possible and focus on providing the project-specific information needed for
the staff to complete environmental reviews of issues that cannot be addressed generically.

11
12
13
14
15
16
17
18
19
20
21

The staff will be able to streamline environmental reviews by referring to the generic analyses in
this GEIS whenever possible and focus their review efforts on environmental issues where a
consideration of project-specific information is needed to ascertain the potential for significant
environmental impacts. Upon receipt of specific new nuclear reactor licensing applications, the
staff will prepare SEISs tiered4 from this GEIS, in accordance with the associated rule, that
briefly identify the environmental issues that can be addressed through this GEIS and then
cover the remaining issues in more detail using project-specific information. The staff expects
that use of this GEIS along with the SEIS will reduce the time and resources needed to
complete environmental reviews, while still providing decision-makers and the public with a
complete and robust analysis of potential environmental impacts and meeting all NEPA
requirements.

22
23
24

Applicants for a construction permit and operating license or a combined license for a nuclear
reactor are required as part of their application to submit a safety analysis report and an ER.
The NRC then performs a safety review which results in a safety evaluation report and an
4

The process of tiering is described in 10 CFR Part 51, Subpart A, Appendix A.

1-18

1
2

environmental review that results in an EIS. This GEIS does not evaluate the safety of a reactor
design; that is a separate review done when an application is submitted.

3
4
5
6

Every 10 years, the Commission intends to review the material in this NR GEIS and the
associated rule and update it if necessary. A scoping notice will be published in the Federal
Register inviting public comments and proposals for other areas that should be updated and
indicating the results of the NRC’s review.

The implementation of the rule is described in more detail below.

1.4.1

General Requirements

9
10
11
12
13
14
15

The regulatory requirements for conducting a NEPA review for a new nuclear reactor are the
same as the requirements for other plant licensing actions. Consistent with the current NEPA
practice for plant licensing actions, an applicant will be required to submit an ER that assesses
the environmental impacts associated with the proposed action, consider alternatives to the
proposed action, and evaluate any alternatives for reducing adverse environmental effects. For
a new nuclear reactor license using this NR GEIS, the NRC will prepare a draft SEIS to this
GEIS for public comment and issue a final SEIS after considering public comments on the draft.

1.4.2

17
18
19
20
21
22
23
24
25
26
27
28
29

The applicant’s ER must contain an assessment of the environmental impacts of constructing
and operating a nuclear reactor and alternatives that meet the purpose and need. In preparing
the analysis of environmental impacts contained in the ER, the applicant should refer to the
information provided in Table C-1 of 10 CFR Part 51 (TN250). The applicant is not required to
assess the environmental impacts of Category 1 issues listed in Table C-1 if (1) the applicant
has demonstrated that its project is bounded by the applicable PPE and SPE values and
assumptions in Table C-1, and (2) the applicant has not identified any new and significant
information that would change the conclusions in this GEIS. If a value or assumption is not met,
then the applicant may be able to limit its analysis to just the impact of not meeting the value or
assumption. Similarly, if the applicant identifies new and significant information that would
change the conclusions in this GEIS, then the applicant may be able to limit its analysis to just
the impact of the new and significant information. For Category 2 issues listed in Table C-1, the
applicant must provide a project-specific assessment of the impacts.

1.4.3

31
32
33
34
35

As required by 10 CFR 51.20(b)(2) (TN250), the NRC will be required to prepare a SEIS to this
GEIS for each new nuclear reactor application using this NR GEIS. The SEIS will serve as the
NRC’s analysis of the environmental impacts of issuing a new nuclear reactor license and will
compare those impacts to the environmental impacts of the alternatives. This document will also
present the NRC’s recommendation to approve or deny the proposed action.

1.4.4

37
38
39
40
41

For a SEIS, the NRC will conduct scoping to inform the public about the licensing process, and
typically will hold public scoping meetings to receive comments about the scope of the NRC’s
plant-specific environmental review. At the conclusion of the scoping period, the NRC will review
and address public comments in a scoping summary report. In addition, the draft SEIS will be
issued for public comment (see 10 CFR 51.73; TN250). In both the scoping and the SEIS public

Applicant’s Environmental Report

The NRC’s SEIS

Public Scoping and Public Comments

1-19

1
2
3
4
5

comment process, the NRC will consider comments and will determine whether the comments
provide any information that is new and significant compared to information previously
considered in this GEIS (for Category 1 issues). If the comments are determined to provide new
and significant information that could change the conclusions in this GEIS, these comments will
be considered and addressed in the SEIS.

1.4.5

The NRC’s Draft SEIS

7
8
9
10
11
12
13
14
15

The NRC’s draft SEIS will include its analysis of the environmental impacts of the proposed
action and the environmental impacts of the alternatives to the proposed action. The NRC will
use and integrate (1) the environmental impacts of the proposed action as provided in Table C-1
of 10 CFR Part 51 (TN250) for Category 1 issues, (2) the appropriate plant-specific analyses of
Category 2 issues, (3) other project-specific information necessary to support the analyses (see
Section 1.3.3), and (4) any new and significant information identified in the applicant’s ER or
during the scoping and public comment process, to arrive at a conclusion regarding the
environmental impacts of issuing a new nuclear reactor license. These impacts will be
compared to the environmental impacts of the alternatives presented in the SEIS.

1.4.6

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The NRC will issue a final SEIS in accordance with 10 CFR 51.91 and 51.93 (10 CFR Part 51TN250) after considering (1) the public comments, (2) the analysis of Category 2 issues, and
(3) any new and significant information involving Category 1 issues. The NRC will provide a
record of its decision regarding the environmental impacts of the proposed action (see 10 CFR
51.102 and 51.103). All comments on the draft SEIS will be addressed by the NRC in the final
SEIS in accordance with 10 CFR 51.91(a)(1).

The NRC’s Final SEIS

1-20

DESCRIPTION OF PROPOSED ACTION AND ALTERNATIVES

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The term “alternatives” is used two ways in this GEIS. The first use refers to alternatives to the
proposed action of issuing the GEIS. Only those alternatives, outlined below in Section 2.1, are
compared in the GEIS and considered in the record of decision for the GEIS. The other use
refers to alternatives to building and operation of a specific nuclear reactor. It is possible to
identify those alternatives only after identification of a specific project on a specific site. The
NRC staff will evaluate and compare such alternatives in a supplemental EIS (SEIS) issued
following receipt of each individual new nuclear reactor licensing application.

2.1

Proposed Action and Alternatives to the GEIS

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The staff developed the following proposed action and alternatives in response to the purpose
and need outlined in Section 1.1. These alternatives were developed and informed by an
exploratory process completed in January 2020, involving interested stakeholders and through
the public scoping process that concluded in May 2020.

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2.1.1

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The proposed action is for the NRC to issue a GEIS containing generic analyses of the
environmental impacts of building and operation of a hypothetical nuclear reactor on a
hypothetical site. The generic analyses for each Category 1 issue would be bounded by the
plant design values and assumptions in the PPE and by the site condition values and
assumptions in the SPE presented in Appendix G. The values and assumptions in Appendix G
are performance-based, where performance reflects minimization of potential environmental
impacts by the applicant when choosing a plant design and site prior to submitting an
application. The values and assumptions are based on environmental conditions and impact
levels below which the staff believes that they may rely on a generic analysis to confidently
conclude that environmental impacts would be SMALL for any location within the United States.

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This GEIS presents generic analyses for Category 1 issues, for which a meaningful impact
assessment is possible based on reasonable values and assumptions in the PPE and SPE.
Category 2 issues include those environmental issues for which a meaningful generic analysis
of environmental impacts is not possible without consideration of project-specific information. As
such, analysis of Category 2 issues is not included in this GEIS.

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Once this GEIS is issued, applicants will be able to rely on and reference the generic analyses
for each Category 1 issue for which the proposed project is bounded by the PPE and SPE
values and assumptions, thereby streamlining the environmental reviews associated with a new
nuclear reactor application. The NRC staff will likewise be able to reference the generic
analyses when it prepares a SEIS in response to an application, thereby simplifying and
streamlining the environmental reviews. Instead of developing individual analyses specific to all
environmental issues in any proposed new nuclear reactor ER or SEIS, applicants and NRC
staff may focus their efforts on the environmental issues that require individualized
consideration of project-specific information (Category 1 issues where the proposed project
is not bounded by the PPE and SPE values and assumptions, and Category 2 issues)
to address the potential for significant environmental impacts. The shorter, more
focused ERs and SEISs will help NRC staff and decision-makers concentrate on issues for
which there is potential for significant environmental impacts.

Proposed Action: Issue Technology-Neutral GEIS Based on Performance-Based
Assumptions

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2.1.2

No-Action Alternative: No GEIS – Project-Specific National Environmental Policy
Act Review Only

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Under the No-Action Alternative, the NRC staff would not develop a GEIS for new nuclear
reactors. Without the availability of a GEIS, applicants for licensing new nuclear reactors would
have to address all relevant environmental issues individually in their ERs, and staff would have
to prepare individual EISs for each application received that address all relevant environmental
issues (including all Category 1 and Category 2 issues). The processes for an applicant to
prepare an ER and for the NRC staff to prepare an EIS would remain similar to those used in
the past for new reactor licensing applications. Regardless of whether the licensing review
process uses a GEIS or not, the actual environmental impacts of the project are the same.
However, the No-Action Alternative would accomplish none of the benefits intended by the
preparation of this GEIS, which would include (1) reducing the time and resources for the
applicant’s preparation of the ER, (2) reducing the time and resources for the NRC staff’s
preparation of the EIS, and (3) focusing the effort of applicant, NRC staff, and decision-makers
on issues that involve a potential for significant environmental impacts. Because the No-Action
Alternative would result in the same level of project-specific impacts without the benefit of
streamlining provided by the GEIS, the NRC staff concludes that the No-Action Alternative is not
environmentally preferable to the proposed action.

2.1.3

2.1.3.1

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Prior to scoping, the NRC staff contemplated preparing a GEIS that would analyze the potential
environmental impacts of a hypothetical reactor that has a power level of approximately 30 MWt
or less on a hypothetical site. The analytical approach to developing the GEIS would have been
similar to that used under the proposed action, but the PPE/SPE would have been developed
based on a typical reactor of 30 MWt, thereby limiting the range of reactors for which the GEIS
would have been useful. Use of the power-level–based GEIS by applicants for small reactors
and NRC staff would have been the same as for the environmental performance-based GEIS
called for in the proposed action. During the scoping process, multiple commenters suggested
that the parameters used in the generic analyses should be tied to the potential for
environmental impacts rather than to an arbitrary power level. After reviewing the comments,
the staff agreed that a GEIS developed using performance-based values and assumptions tied
to environmental impacts might help streamline environmental reviews even for some larger
advanced nuclear reactors that would still have a low potential for significant environmental
impacts with respect to some environmental issues.

2.1.3.2

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The NRC staff initially developed this GEIS as a document that would be applicable to only
advanced nuclear reactors. See SECY-21-0098, Proposed Rule: Advanced Nuclear Reactor
Generic Environmental Impact Statement, dated November 29, 2021. However, in
SRM SECY-21-0098, dated April 17, 2024, the Commission directed the NRC staff to change
the limited applicability of this GEIS from solely “advanced nuclear reactors” to any new nuclear
reactor licensing application, provided the application meets the values and the assumptions of
the plant parameter envelopes and the site parameter envelopes used to develop the GEIS.
Based on the direction from the Commission, the alternative of developing a GEIS that would be
applicable to only advanced nuclear reactors will not be considered further.

Other Alternatives Considered but Not Analyzed in Detail
Limiting the GEIS to Reactors Less than 30 MWt

GEIS for Advanced Nuclear Reactors Only

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2.1.3.3

GEIS Analyzing All Potential Environmental Impacts

The staff also considered whether it would be possible to develop a GEIS that could serve as
the sole technical documentation of potential environmental impacts for any new nuclear
reactor. However, the staff concluded that it is not technically possible to develop generic
analyses addressing all potentially significant environmental impacts from any new nuclear
reactor without consideration of site-specific and project-specific conditions. Reliance on such a
GEIS would not meet the NRC’s regulations in Title 10 of the Code of Federal Regulations
Part 51 (TN250) for compliance with the National Environmental Policy Act of 1969 (42 U.S.C.
§§ 4321 et seq.; TN661). The GEIS would also not meet the requirements of other
environmental laws, such as the Endangered Species Act (16 U.S.C. §§ 1531 et seq.; TN1010)
or the National Historic Preservation Act (54 U.S.C. §§ 300101 et seq.; TN4157).

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AFFECTED ENVIRONMENT AND ENVIRONMENTAL
CONSEQUENCES

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This chapter of the GEIS describes the affected environment and environmental consequences
resulting from building and operation of a nuclear reactor. This introduction describes the
concept and background behind the development and analysis of the baseline, the values and
assumptions bounding the PPE and SPE and impacts from building and operation on the
environmental resources. This chapter is organized into subsections that address each of 16
relevant environmental resources that the NRC staff identified following the scoping process
outlined in Chapter 1.

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• Overview of Affected Environment. The baseline condition described as the “affected
environment” in this GEIS is the environment that exists at and around a site proposed for
building and operation of a nuclear reactor. A site could be anywhere in the United States or
its territories that meets NRC reactor siting criteria in Title 10 of the Code of Federal
Regulations Part 100 (10 CFR Part 100; TN282). The affected environment reflects the
existing condition of environmental resources, as influenced by natural physical conditions
and by past human activities such as agriculture, forestry, mining, urbanization, and
industrial and non-industrial development. The site might be situated at an existing nuclear
power plant property, and, if so, the generalized description of the affected environment at
an existing nuclear power generation site presented in the License Renewal GEIS (NRC
2024-TN10161) might be informative. However, new nuclear reactors might also be
proposed for sites not previously used for nuclear power generation. New nuclear reactors
might be proposed for sites that have a history of industrial use or other development, or
they might be proposed for greenfield sites that have not been previously developed other
than for agricultural, forestry, or conservation purposes. New nuclear reactors might be
proposed for sites on government-owned or managed installations such as military bases or
national laboratories, or they might be proposed for privately owned sites.

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The range of existing environmental conditions that might possibly occur at any possible
proposed site is too broad to characterize. The NRC staff instead developed the PPE and SPE
values and assumptions presented in Appendix G. An application for a license that references
this GEIS and for which the reactor and site meet the PPE and SPE values and assumptions for
a Category 1 issue will be able to rely on the generic environmental impact analyses and
conclusions for that issue in this GEIS. If the PPE or SPE values and assumptions relevant to
an environmental impact are not met, the applicant will have to perform an analysis of that
impact in the ER using project-specific environmental information. Relevant project-specific
information would be presented in an application for a license that references the GEIS and in
the NRC’s supplemental environmental review documentation.

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Each resource-specific section that follows discusses the affected environment in terms of
baseline conditions and the PPE and SPE values and assumptions as they relate to that
resource.

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• Overview of Environmental Consequences. This chapter also evaluates the potential
environmental consequences of building, operation, fuel cycle, and decommissioning of a
nuclear reactor that meet the values and assumptions for the parameters in the PPE and
SPE. Each subsection identifies specific environmental issues involving the possible
impacts of a new nuclear reactor on the subject resource. Each subsection then presents
generic analyses of potential environmental impacts for each issue for which a generic

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analysis is possible (i.e., Category 1 issues), assuming that all of the PPE and SPE values
and assumptions for that issue are met. Each environmental issue is defined as either a
Category 1 or a Category 2 issue.

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The basis for identifying an issue as being a Category 1 issue is whether a generic analysis of
the issue is sufficient for decision-makers and the public when licensing a new nuclear reactor
that meets the values and assumptions in the PPE and SPE. The generic analyses for all issues
identified by the NRC staff as Category 1 issues support determinations of SMALL impacts. In
general, however, individualized analyses that consider project-specific information are
necessary for impacts of greater than SMALL significance. In addition, the fact that an
individualized analysis is necessary does not mean that the supplemental environmental
documentation will conclude that impacts pertaining to the issue will be greater than SMALL; it
only means that more than a generic analysis is necessary to reach that conclusion.

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The generic analyses presented in this chapter assume possible mitigation measures on a
resource-specific basis developed on a generic basis to reduce adverse environmental impacts.
If a proposed new nuclear reactor application meets the PPE and SPE values and assumptions,
including mitigation, pertaining to an environmental issue, then the generic assessment can be
relied upon in the SEIS. The staff will always individually consider the possible mitigation
measures for Category 2 issues.

3.1

3.1.1

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Baseline conditions influencing potential land use impacts associated with construction and
operation of a new nuclear reactor include past and present land uses and land cover on and
surrounding the site, applicable zoning regulations, and relevant planning documents such as
comprehensive land use plans or installation land use plans. Land use conditions relevant to the
environmental analysis include the plant site and surroundings but also offsite land (and
surroundings) for affiliated uses such as construction laydown and intake and discharge
structures, and any offsite rights-of-way (ROWs) for transmission lines, pipelines, or heavy-haul
roads.

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In developing the values and assumptions in the PPE and SPE pertaining to land use, the staff
relied upon the information and analyses contained in multiple new reactor EISs prepared since
2005, the License Renewal GEIS (NRC 2024-TN10161), other past NRC EISs, and common
elements of State and local land use regulation. Some assumptions made in this section of the
GEIS involve parameters and values that are developed based on previous staff environmental
reviews or are the subject of Federal and State regulations; some have been appropriately
scaled down to account for the size and technology differences between large LWRs and
potential smaller new nuclear reactors. In every case, the NRC staff has selected a value or
parameter that will ensure a minimal impact on land use from construction and operation of a
nuclear reactor after considering all available information and leveraging professional judgment
and expertise. The NRC staff’s assumptions that support the PPE and SPE are described
below.

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In addition to assuming that any proposed facilities would comply with NRC siting regulations in
10 CFR Part 100 (TN282), the staff assumes that the proposed plant site would be no larger
than 100 ac, within which site disturbance would affect no more than 30 ac of land permanently
and no more than 20 ac of additional land temporarily. The staff also assumes that the site

Land Use
Baseline Conditions and PPE/SPE Values and Assumptions

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would be at least 0.5 mi from the nearest existing residence. The staff established these values
to ensure that dedication and disturbance of land in most settings could not substantially
interfere with nearby land uses or alter regional land use characteristics and trends. The staff
also assumes that construction and operation of a power plant would be consistent with
applicable zoning and with the objectives of any local land use plans (typically prepared for
counties or multi-county planning areas). Reliance on zoning compliance and compatibility with
land use plans underlie conclusions regarding minimal land use impacts in all recent new
reactor EISs, as well as most EISs prepared for other major land development projects. The
staff assumes that any cooling towers built on the site would be mechanical draft towers under
100 ft in height rather than the taller natural draft cooling towers. Taller cooling towers can
generate drift capable of affecting sensitive land uses, such as residential uses, at greater
distances from the towers. Taller towers could also pose a collision risk to birds and other flying
wildlife (see Section 3.5.2.1.5). The staff also assumes that a project would not include salt
evaporation ponds, whose use could potentially result in significant salt deposition in
surrounding residential lands (NRC 2011-TN6437).

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The staff assumes that new offsite ROWs for transmission lines, pipelines, access roads, or
other new linear facilities would be no longer than 1 mi and have a maximum ROW width of
100 ft. However, the assumptions allow for unlimited additional mileage for building new linear
facilities within existing ROWs or adjacent to existing ROWs or public highways, unless in
residential areas. As for the assumed site area values, the staff established the ROW values to
ensure that the offsite ROWs could not substantially interfere with other land uses or alter
regional land use characteristics or trends. For similar reasons, the staff assumes that the site
and ROWs would not be situated closer than 0.5 mi to residential areas or 1 mi to sensitive land
uses such as Federal, State, or local parks, wildlife refuges, conservation lands, Wild and
Scenic Rivers, or Natural Heritage Rivers. The staff also assumes that the land disturbed by
building activities (footprint of disturbance) could be accommodated within the site but still avoid
impacts on more than 0.5 ac of wetlands and other waters of the United States (project wide),
and avoid any encroachment into floodplains, shoreline, or riparian lands that may be within the
site boundaries (although the SPE allows for offsite ROWs to traverse such features). The
0.5 ac limit is based on the fact that many Nationwide Permits under Section 404 of the Clean
Water Act (CWA) (33 U.S.C. § 1344-TN1019) include a project-wide limitation of 0.5 acres (ac)
of wetland loss. The staff also assumes that the site and ROWs do not have a history of past
industrial use capable of leaving a legacy of contamination requiring cleanup to protect human
health or the environment.

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The staff further assumes that projects would comply with NRC siting regulations in 10 CFR
Part 100 (TN282) (including 10 CFR 100.20 – Factors to be considered when evaluating sites;
10 CFR 100.21 – Non-seismic siting criteria; and 10 CFR 100.23 – Geologic and seismic siting
criteria), the Coastal Zone Management Act of 1972 (CZMA; 16 U.S.C. §§ 1451 et seq.;
TN1243) and the Farmland Protection Policy Act (FPPA; 7 U.S.C. §§ 4201 et seq.; TN708),
including implementation of any mitigation measures necessary for compliance with these
statutes and regulations. The staff will include the findings made and the data gathered as a
result of this compliance in its evaluation of land use impacts, as applicable (NRC 2000-TN614).
Under the CZMA, each State bordering the tidal waters of the oceans or the Great Lakes has
the opportunity to identify its coastal zone and issue a plan for managing land use in that zone
that balances the objectives of conservation and economic development. The CZMA is a
voluntary program for States (16 U.S.C. § 1451(i) and 1452(2) and (4)). If a State has decided
to participate in the CZMA program, then compliance with the CZMA is necessary for all reactor
licensing projects sited in that State’s coastal zone, in accordance with the State’s coastal
management program (16 U.S.C. § 1456(c)). Additionally, if an applicant proposes to construct

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and operate a reactor outside of the State’s coastal zone, compliance with the CZMA may still
be required to the extent that the proposed project may have a reasonably foreseeable effect
upon offsite coastal zone land uses or resources (15 CFR 930.33(a)(1); TN4475). The State’s
coastal management program is approved by the National Oceanic and Atmospheric
Administration, of the U.S. Department of Commerce.

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The staff assumes there is no prime or unique farmland, or other farmland of statewide or local
importance within the footprint of disturbance, unless the site does not abut other agricultural
areas and is situated in a predominantly agricultural setting. The purpose of the FPPA is to
minimize the extent that Federal programs contribute to the unnecessary and irreversible
conversion of farmland to nonagricultural uses. The FPPA defines three categories of regulated
farmland namely, prime farmland, unique farmland, and farmland of State or local importance.
Prime farmland means “land that has the best combination of physical and chemical
characteristics for producing food, feed, fiber, forage, oilseed, and other agricultural crops with
minimum inputs of fuel, fertilizer, pesticides, and labor, and without intolerable soil erosion,” as
determined by the Secretary of the U.S. Department of Agriculture (7 U.S.C. 4201(c)(1)(A)).
Prime farmland includes land that possesses the above characteristics but is being used
currently to produce livestock and timber. Prime farmland does not include land already in or
committed to urban development or water storage. Unique farmland means “land other than
prime farmland that is used for production of specific high-value food and fiber crops, as
determined by the Secretary. It has the special combination of soil quality, location, growing
season, and moisture supply needed to economically produce sustained high quality or high
yields of specific crops when treated and managed according to acceptable farming methods”
(7 U.S.C. § 4201(c)(1)(B); TN708). Examples of crops grown on unique farmland include citrus
fruits, olives, and cranberries. The third category is farmland, other than prime or unique
farmland, which is determined to be of State or local significance as determined by the
appropriate State or local agency with the concurrence of the U.S. Department of Agriculture
Secretary (7 U.S.C. § 4201(c)(1)(C)).

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The FPPA does not apply to Federal permitting and licensing (7 U.S.C. § 4208(a); TN708),
including the issuance of an NRC license for a reactor, unless the reactor is to be constructed or
installed on federally owned or leased land that falls under one of the above-described FPPA
categories. If the reactor is to be located on such federally owned or leased land, then the NRC
must consider the impacts of its proposed action in accordance with the FPPA. Even if the
FPPA does not apply to an action, impacts on farmland still constitute an environmental
consideration in the context of NEPA. The FPPA definitions include land mapped by the Natural
Resources Conservation Service that feature soils possessing optimal physical and climatic
properties for food and fiber production, even if the soils are not actually in agricultural use.
Soils with a past history of disturbance for urban development are excluded from the farmland
designations used in the FPPA.

3.1.2

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Most land use impacts from new nuclear reactors would take place during the preconstruction
and construction phases of the project. Evaluation requires consideration of the proposed
safety-related facilities such as the nuclear island as well as non-safety-related facilities such as
cooling towers, administration buildings, parking lots, switchyards, and any onsite and offsite
pipelines, access roads, and transmission lines. Many smaller nuclear reactors may be housed
in one or a few small buildings on a site of less than a few acres and may lack cooling towers,
switchyards, or offsite pipelines or transmission lines. Larger nuclear reactors may require some
or all of these support facilities and hence larger sites exceeding the site and disturbance area

Land Use Impacts

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assumptions. Land uses are unlikely to substantially change during operation of a nuclear
reactor, although minor land use changes could be necessary to refurbish or upgrade a nuclear
reactor during its operational life (NRC 2024-TN10161).

3.1.2.1

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The staff’s evaluation of land use impacts for building a nuclear reactor focused on land use
changes being consistent with potentially applicable zoning and land use plans. The NRC staff
identified four land use issues for analysis of the building of a nuclear reactor:

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Environmental Consequences of Construction

• onsite land use, especially the compliance of onsite land uses with zoning and land use
plans and compatibility with adjacent and nearby land uses;

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• offsite land use, especially the compatibility of offsite linear facilities such as pipelines and
transmission lines with adjacent land uses;

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• potential impacts on prime farmland, unique farmland, and farmland of State or local
significance; and

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• CZMA compliance for a nuclear reactor to be constructed or installed at a site within a
designated coastal zone or at a site outside of a coastal zone but the construction or the
installation of the reactor may have a reasonably foreseeable effect upon a coastal zone use
or resource.

3.1.2.1.1 Onsite Land Use

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The PPE and SPE assume that the new nuclear reactor would require the dedication of a site
no larger than 100 ac in area, within which site disturbance would affect no more than 30 ac of
land permanently and no more than 20 ac of land temporarily. A site of that size would likely be
large enough to accommodate any exclusion areas required under 10 CFR Part 100 (TN282).
Use of a site of that size is unlikely to noticeably affect the availability of land for other purposes
in most settings that are rural enough to meet the NRC siting criteria for a nuclear reactor in
10 CFR Part 100. Existing land use within the 30 ac of permanently disturbed land would be
converted to industrial land use. The remainder of the site would be available for management
as buffer land surrounding the new facilities and could be left in existing natural vegetation,
agricultural land uses, or other uses that do not encroach on the exclusion area defined in
10 CFR Part 100 or interfere with reactor operations. As required by 10 CFR Part 100, no land
uses unrelated to operation of the reactor would be allowed within the exclusion area, although
conservation and management of natural vegetation would be allowed. The staff assumes that
the 20 ac of temporarily disturbed land would be restored to regionally indigenous vegetation
and then be available for other allowable land uses (if it is outside of the exclusion area defined
in 10 CFR Part 100). The analysis recognizes that the entire 100 ac site would be unavailable
for other industrial, commercial, residential, or recreational land uses until after the reactor is
fully decommissioned.

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The assumptions in Section 3.1.1 include compliance with applicable zoning ordinances and
compatibility with any comprehensive land use plans adopted by local governments or planning
agencies for the affected area. Zoning ordinances and land use plans are prepared to ensure
that future development projects are compatible with other existing and reasonably foreseeable
land uses in the area. The ordinances and plans also strive to ensure that adequate land is
available for reasonably foreseeable competing land use demands. Land use plans are also
often prepared by government agencies or contractors for national laboratory properties or
military bases. These plans help ensure that new land uses are compatible with the facility’s

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mission and conservation objectives. The assumption in Section 3.1.1 that the site is at least
0.5 mi from existing residential areas further reduces the risk that the proposed new facilities
might interfere with nearby residential properties. Constructing or installing a reactor of a size
encompassed by the PPE and fitting onto a site featuring the size and disturbance limitations
noted above would attract only a limited construction workforce for a temporary period of time,
which should not noticeably alter land use patterns in the surrounding landscape.

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The NRC staff has determined that onsite land use during the building of a nuclear reactor is a
Category 1 issue. The staff concludes that as long as the assumptions outlined in Section 3.1.1
for the site are met, then impacts from building a nuclear reactor can be generically determined
to be SMALL. The staff relied on the following PPE and SPE values and assumptions to reach
this conclusion:

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• The proposed project, including any associated land uses, complies with NRC siting
regulations in 10 CFR Part 100 (TN282).

• The site size is 100 ac or less.

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• The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and the
temporary footprint of disturbance includes no more than an additional 20 ac or less of
vegetated lands.

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• The proposed project complies with the site’s zoning and is consistent with any relevant land
use plans or comprehensive plans.

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• The site would not be situated closer than 0.5 mi to existing residential areas or 1.0 mi to
sensitive land uses such as Federal, State, or local parks; wildlife refuges; conservation
lands; Wild and Scenic Rivers; or Natural Heritage Rivers.

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• The site does not have a history of past industrial use capable of leaving a legacy of
contamination requiring cleanup to protect human health and the environment.

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• The total wetland loss from use of the site, including use of any offsite ROWs, would be no
more than 0.5 ac.

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• Best management practice (BMPs) for erosion, sediment control, and stormwater
management would be used.

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• Compliance with any mitigation measures established through zoning ordinances, local
building permits, site use permits, or other land use authorizations.

3.1.2.1.2 Offsite Land Use

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A project meeting the assumptions outlined in Section 3.1.1 would establish no more than 1 mi
of new offsite ROW that is no more than 100 ft in width, although unlimited offsite linear
development within or adjacent to existing ROWs or roadway is assumed. Any required
acquisition of land or easements is also assumed to be obtained from willing landowners without
resorting to use of eminent domain.1 Development of 1 mi of ROW that is no more than 100 ft in
width would result in conversion of approximately 12.1 ac of existing land cover to land
managed for a utility ROW. Forest cover, whether natural or managed, would be removed and
converted to managed grassland, scrubland, or other land cover compatible with management
of the ROW. It might be possible to continue the current use of some land in the ROW during
and after the utility line construction or installation for cropland, pasture, orchards, or range, or
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The NRC would not engage in eminent domain on behalf of an applicant or licensee.

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for outdoor recreation or conservation, although some land uses would be permanently
converted to build access roads, transmission towers, or other facilities.

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Establishment of new ROWs across existing land uses could fragment properties and interfere
with existing or potential uses, but those effects would be minimized in most settings by the 1 mi
limitation on new ROW length not co-located with or adjoining existing ROWs or roadways. The
presence of ROWs and especially overhead transmission conductors could interfere with some
agricultural operations such as aerial pesticide spraying and pivot irrigation. The presence of the
ROW would not likely interfere with abutting or nearby land uses, although it could be perceived
as undesirable when abutting or close to residential, recreational, or educational land uses.

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Other than in residential areas, use of existing ROWs has little potential for the types of land use
impacts described above for establishing new ROWs. Building utilities such as transmission
lines within existing ROWs, including existing roadway ROWs, would not expose additional
existing land uses to the presence of a ROW. Widening existing ROWs to accommodate new
offsite utilities would also not fragment other land uses and is much less likely to interfere with
other land uses or be perceived as incompatible. Additional land might be affected by widening
existing ROWs, but the widened ROWs would not fragment additional land uses or expose new
land uses to the presence of adjacent transmission lines or other linear utilities. However, the
staff recognizes that widening an existing ROW, or even new work within an existing ROW,
could have impacts in residential areas, where a consideration of site-specific conditions could
be necessary to determine potential effects on residential properties.

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The NRC staff has determined that offsite land use during construction of a nuclear reactor is a
Category 1 issue. The staff concludes that as long as the PPE and SPE values and
assumptions outlined in Section 3.1.1 for the offsite ROWs are met, the impacts of building
offsite linear features associated with a nuclear reactor can be generically determined to be
SMALL. The staff relied on the following PPE and SPE values and assumptions to reach this
conclusion:

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

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• No new offsite ROW would be situated closer than 0.5 mi to existing residential areas or
sensitive land uses such as Federal, State, or local parks; wildlife refuges; conservation
lands; Wild and Scenic Rivers; or Natural Heritage Rivers.

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• No existing ROWs in residential areas would be used or widened to accommodate project
features.

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• No ROW has a history of past industrial use capable of leaving a legacy of contamination
requiring cleanup to protect human health and the environment.

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• The total wetland loss from use of the entire project, including use of the site and any offsite
ROWs, would be no more than 0.5 ac.

• BMPs for erosion, sediment control, and stormwater management would be used.

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• Compliance with any mitigation measures established through zoning ordinances, local
building permits, site use permits, or other land use authorizations.

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3.1.2.1.3 Impacts on Prime and Unique Farmland

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The PPE and SPE assume that the site is no larger than 100 ac and does not contain any prime
or unique farmland, or other farmland of statewide or local importance, as defined in the FPPA
(7 U.S.C. §§ 4201 et seq.; TN708). The assumptions do, however, allow for the presence of
prime or unique farmland on the site as long as the site does not abut other land actively
managed for agricultural purposes and does not occur in a predominantly agricultural
landscape.

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Loss of less than 100 ac of land optimal for agricultural use is unlikely to substantially affect
regional agricultural production if the affected land is not positioned close to other agricultural
land. Building transmission lines and other structures bounded by the PPE and SPE in offsite
ROWs is also unlikely to adversely affect the use of farmland, including farmland regulated
under the FPPA. Establishing up to 1 mi of new offsite ROW would affect no more than
approximately 12.1 ac of farmland. Additional farmland could be affected by widening ROWs but
would not experience the effects of fragmentation by the presence of new utility structures. Not
all of the affected land would necessarily be excluded from agricultural use, because farming
could continue under transmission conductors and over the top of backfilled pipeline and buried
utility trenches. Some of the soils in the ROW could be disturbed to excavate trenches or build
towers or access roads, thereby permanently altering the physical properties of the soils that
make them optimal for agricultural use. However, the small area of disturbance allowed within
the PPE and SPE ensures that the agricultural effects would be low.

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The NRC staff has determined that prime and unique farmland during construction of a nuclear
reactor is a Category 1 issue. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:

• The site size is 100 ac or less.

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The site does not contain any prime or unique farmland or other farmland of statewide or local
importance; or the site does not abut any agricultural land and is not situated in a predominantly
agricultural landscape. The generic analysis can be relied on without conducting any mitigation
measures. If the site includes any federally owned land (or if the applicant is itself a Federal
agency), however, the agency charged with managing the land must demonstrate compliance
with the FPPA by consulting with the Natural Resources Conservation Service, which may
specify mitigation measures. However, the FPPA exempts actions not affecting federally owned
land, even if the actions require permits or involve the acceptance of funding from Federal
agencies.

3.1.2.1.4 Coastal Zone and Compliance with the Coastal Zone Management Act

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The NRC staff has determined that impacts on the coastal zone during the construction or
installation of a nuclear reactor is a Category 1 issue. The NRC cannot license an activity
affecting the designated coastal zone without the applicant documenting that it has received a
consistency determination from the applicable State agency. The State agency will not issue a
consistency determination under the Act unless the potential impacts from the activity on the
coastal zone are shown to be minimal or otherwise appropriately mitigated. The staff expects
that only minimal impacts on the coastal zone will result from the construction/installation and
operation of a reactor meeting the PPE criteria on a site meeting the SPE criteria. The staff
concludes that any potential impacts on the coastal zone would be SMALL provided the
applicant receives a CZMA consistency determination from the applicable State agency. The
staff relied on the following PPE and SPE assumption to reach this conclusion:
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• The site is not situated in any designated coastal zone, or the applicant can demonstrate
that the affected state(s) have or will issue a consistency determination or other indication
that the project complies with the Coastal Zone Management Act.

3.1.2.2

Environmental Consequences of Operation

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The NRC staff recognizes that the greatest potential for adverse land use impacts is during
construction, when existing land cover at the site is altered to build the reactor and supporting
facilities. Nevertheless, the staff identified two environmental issues for analysis of land use
impacts from operation of a nuclear reactor:

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• onsite land use, especially possible land use changes on the site during operation of a
reactor; and

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• offsite land use, especially land use changes within ROWs during operation of offsite linear
facilities such as pipelines and transmission lines.

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Once the project has been built, further impacts on prime and unique farmland or the coastal
zone are not a potential concern.

3.1.2.2.1 Onsite Land Use

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Once a site has been developed with a nuclear reactor, onsite land use would not substantially
change over the course of operations. It is possible that small areas of land cover within the site
could be temporarily or permanently disturbed as facilities are maintained or refurbished or to
accommodate additional support facilities such as expanded parking lots. However, the entire
site would still be dedicated to the reactor throughout its operational life and the overall
character of the site would remain unchanged. Land use restrictions in the exclusion areas
would remain restricted in accordance with 10 CFR Part 100 (TN282) throughout operations.
The licensee may initiate new uses of other land within the site, such as management of
undeveloped land for agriculture or conservation or for other land uses not regulated by the
NRC, but those actions would not constitute substantial land use changes within a site not
exceeding the PPE of 100 ac. If the licensee has obtained permission from the NRC to build
and operate an onsite storage facility on the site, the NRC staff has already determined on
page 4-3 and 4-5 of the continued storage GEIS that land use impacts from building and
operating additional onsite short-term and long-term nuclear fuel storage facilities during the
operational life of the reactor would be SMALL (NRC 2014-TN4117). The continued storage
GEIS recognized that only small areas of land would be needed to build and operate the
facilities and could be accommodated within previously disturbed lands on operating reactor
sites. The analysis presented above is also corroborated by page 4-7 of the License Renewal
GEIS where the staff concluded that onsite land use impacts from operation of the existing large
LWRs would be SMALL (NRC 2024-TN10161).

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The NRC staff has determined that onsite land use during operation of a nuclear reactor is a
Category 1 issue. The staff concludes that, as long as the PPE and SPE values and
assumptions outlined in Section 3.1.1 for the site are met, the land use impacts from operating a
nuclear reactor can be generically determined to be SMALL. The staff relied on the following
PPE and SPE values and assumptions to reach this conclusion:

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• The proposed project, including any associated land uses, complies with NRC siting
regulations in 10 CFR Part 100.

• The site size is 100 ac or less.

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• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in
height; and equipped with drift eliminators.

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• Any makeup water for the cooling towers would be fresh water (less than 1 part(s) per
thousand [ppt] salinity).

• BMPs for erosion, sediment control, and stormwater management would be used.

3.1.2.2.2 Offsite Land Use

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Once a nuclear reactor is built and begins operation, substantial new offsite land use changes
are unlikely. The staff has determined that the potential for offsite land use impacts from
continued operation of already-built reactors is minimal (NRC 2024-TN10161). It would be
possible to continue use of some land in offsite ROWs for cropland, pasture, orchards, or range,
or for outdoor recreation or conservation. The License Renewal GEIS described studies in
which the presence of overhead electrical transmission conductors somewhat depressed the
yield of cotton, but not rice or soybeans, planted underneath, and attributed the effects either to
the presence of EMFs or physical interference by the conductors with aerial pesticide spraying
(NRC 2024-TN10161). Landowners are, however, compensated for utility easements crossing
their land (unless the utility buys the land underlying the ROW outright), and the indicated yield
suppressions would not limit economically viable agriculture.

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Operation of cooling towers can result in fogging, icing, and salt drift that interfere with offsite
land uses, including agricultural and residential uses. As reported in the original License
Renewal GEIS, a review for possible visible vegetation damage from operation of natural draft
cooling towers at eight nuclear plants across the United States revealed no damage, and a
review for possible visible vegetation damage from 10 nuclear plants that have mechanical draft
cooling towers revealed no damage more than 500 ft from the towers (NRC 1996-TN288). The
PPE and SPE assume that natural draft cooling towers, which are taller and hence capable of
depositing drift farther away from the towers, would not be used; however, the fact that even
they have been shown to result in minimal drift effects supports an assertion that drift impacts
have only minimal potential to affect land outside of a power plant site. Furthermore, the PPE
and SPE assume that there are no existing (at the time of licensing) residential properties within
0.5 mi of the site, including any cooling towers, thereby ensuring conservatism with respect to
the potential for drift-related impacts. The analysis presented above is also corroborated by the
current License Renewal GEIS in which the staff concluded that onsite land use impacts from
operation of the existing large LWRs would be SMALL (NRC 2024-TN10161).

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Operation of any new nuclear reactor would result in increased employment in the surrounding
region, possibly requiring the use of land to provide additional housing and services. However,
accommodating any increase in regional population growth for operation of a nuclear reactor, as
outlined in the PPE and SPE for the socioeconomic analysis in Section 3.12, is unlikely to result
in enough increased regional development by housing and support services to lead to
noticeable adverse competition for offsite land resources in most economic regions.

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The staff has determined that offsite land use during operations of a nuclear reactor is a
Category 1 issue. The staff concludes that as long as the PPE and SPE values and
assumptions outlined in Section 3.1.1 for the offsite ROWs are met, the impacts can be
generically determined to be SMALL. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

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• BMPs for erosion, sediment control, and stormwater management would be used (wherever
land is disturbed during the course of ROW management).

3.2

3.2.1

Visual Resources
Baseline Conditions and PPE/SPE Values and Assumptions

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Baseline conditions influencing visual impacts include land cover and topography on the
proposed site and surrounding landscape, weather patterns and conditions, the height of any
existing structures and vegetation on the property, the proximity to other uses of the site, the
extent of viewsheds (the area visible from a location sensitive to visual impacts, such as a
residence or a park), and other landscape characteristics. Visual effects depend greatly on the
setting. A nuclear power plant that might be visually obtrusive in residential or tourist settings
might not raise any visual objections in areas where industrial or power generation facilities are
common. Among the various visual impact assessment methodologies developed by Federal
agencies, one of the best known is the Visual Contrast Rating process, which emphasizes the
visual contrast between development actions and their surroundings (BLM 1986-TN6403).

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In developing the values and assumptions in the PPE and SPE pertaining to visual resources,
the staff relied upon the information and analyses contained in multiple new reactor EISs
prepared since 2005, the License Renewal GEIS (NUREG-1437; NRC 2024-TN10161), other
past NRC EISs, and common elements of State and local land use regulation. In each case,
staff has selected a value or parameter that will ensure a minimal visual impact from
construction and operation of a nuclear reactor after considering all available information and
leveraging professional judgment and expertise. The staff’s assumptions that support the PPE
and SPE are described below.

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Most of the assumptions relevant to visual impacts are also ones outlined in Section 3.1.1 for
land use. In addition, the staff assumes a maximum building and structure height of 50 ft (except
200 ft for meteorological towers and 100 ft for transmission poles/towers and mechanical draft
cooling towers). The staff assumes that projects would not include natural draft cooling towers,
which are typically several hundred feet in height and therefore visible from considerable
distances away from the site in most settings, depending on factors such as vegetation and
topography. The staff also assumes that project structures would not be visible from Federal or
State parks or wilderness areas designated as Class 1 under Section 162 of the Clean Air Act
(42 U.S.C. § 7472; TN6954) or a Wild and Scenic River, a Natural Heritage River, or a river of
similar State designation. The staff acknowledges that many proposed facilities may not be
completely invisible at all times from all sensitive locations such as residences or parks, even if
meeting all of the values and assumptions noted above. The visibility of structures from places
on or eligible for listing on the National Register of Historic Places (NRHP) is addressed in
Section 3.9.

3.2.2

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Context plays a key role in the evaluation of visual impacts; the appearance of industrial
structures in established industrial settings is generally better tolerated than the same structures
in pastoral or residential settings. Taller or larger structures, especially structures of a type not
previously occurring on the landscape, tend to affect the visual properties of landscapes more

Visual Resources Impacts

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than other structures. For example, for the proposed Greene County Nuclear Power Plant,
cancelled in the 1980s because of opposition due to aesthetic concerns, greater opposition was
recorded among members of the public to a natural draft cooling tower than to a cement plant,
an industrial feature already existing in the generally rural landscape (Petrich 1982-TN6810).
Evaluators of visual impacts often speak of effects in terms of viewsheds, defined as the
landscape that can be directly seen under favorable atmospheric conditions, from a viewpoint or
along a transportation corridor (BLM 1984-TN5536). Many smaller nuclear reactors meeting the
assumptions in the PPE and SPE may consist only of, or be housed in, smaller, lower structures
compared to the larger, commercial reactors that have been previously licensed by the NRC.
Such smaller, lower structures meeting the values and assumptions would have little potential
for visual impacts on viewsheds, whether or not those viewsheds contain existing nuclear
facilities or other power generation or industrial facilities.

3.2.2.1

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The NRC staff identified two environmental issues related to visual resources for building a
nuclear reactor:

Environmental Consequences of Construction

• visual impacts from structures on and in the vicinity of the site, and

• visual impacts from transmission lines.

3.2.2.1.1 Visual Impacts in Site and Vicinity

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Projects meeting the values and assumptions outlined in Section 3.2.1 would not likely be
visually obtrusive, even from sensitive features such as residences, parks, and areas
designated for conservation. Not being visually obtrusive does not necessarily imply incapable
of being seen, especially from a distance. Power generation facilities are however industrial in
appearance and would therefore contrast strongly with most natural settings found on greenfield
(previously undeveloped) sites, although they would not likely contrast markedly if built in close
proximity to existing nuclear or other power plants or other industrial facilities. In landscapes that
feature substantial forest cover, structures would likely only be visible close to the site. The
structures might be visible from distant high points or ridges but not be a prominent visual
feature. The structures would be visible for greater distances in open landscapes characterized
predominantly as agricultural, grassland, or scrub cover, but their visual prevalence would
decrease with distance. In a completely open landscape such as the ocean or a grassland with
no trees, the horizon visible to a standing person 6 ft in height would be approximately 3 mi
away; even at distances of only 1 mi, structures would be visible although not prominent. Most
landscapes, however, contain hills, trees, and other features that soften the appearance of
structures relative to a completely open, flat landscape. Little or no change in the overall visual
character of most landscapes would occur if structures meeting the assumed building height
values noted in Section 3.2.1 were built close to existing industrial facilities such as existing
nuclear generation facilities or other power plants, or in industrial parks or industrially developed
areas of military bases. The structures could be aesthetically detrimental to residences or parks
situated close to the site, but the structures would not likely alter the aesthetic quality of
residences or parks more than 1 mi from the site.

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The staff has determined that visual impacts on the site and vicinity are a Category 1 issue. The
staff relied on the following PPE and SPE values and assumptions to reach this conclusion:

• The site size is 100 ac or less.

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• The site would not be situated closer than 0.5 mi to existing residential areas or 1 mi to
sensitive land uses such as Federal, State, or local parks; wildlife refuges; conservation
lands; Wild and Scenic Rivers; or Natural Heritage Rivers.

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• The maximum proposed building and structure height is no more than 50 ft, except that the
maximum height is 200 ft for proposed meteorological towers and 100 ft for transmission line
poles/towers and mechanical draft cooling towers.

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• The proposed project structures would not be visible from Federal or State parks or
wilderness areas designated as Class 1 under Section 162 of the Clean Air Act (42 U.S.C.
§ 7472; TN6954); or as a Wild and Scenic River, a Natural Heritage River, or a river of
similar State designation.

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Note that the generic analysis assumes both that the site and ROWs are not within 1 mi of
exceptionally sensitive areas such as wilderness areas and special-status rivers and that the
proposed new structures would not be visible from these sensitive areas. No visual simulation or
other projection of visual effects is needed to corroborate this conclusion as long as the relevant
PPE and SPE values and assumptions are met. If the PPE and SPE values and assumptions
are met, the applicant does not need to submit visual simulations (such as an artistic rendering)
or other projections of visual effects. Optional mitigation measures that might be considered
include planting trees, earthen berms, walls, or other landscaping activities around any part of
the perimeter of the site.

3.2.2.1.2 Visual Impacts from Transmission Lines

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The assumptions in the PPE and SPE regarding transmission line ROWs and structures (poles
or towers) ensure that the visual effects of any new transmission lines serving a nuclear reactor
project would be minimal and that the visual integrity of sensitive features such as parks,
wilderness areas, conservation lands, Wild and Scenic Rivers, and American Heritage Rivers
would not be compromised. Transmission towers, poles, and conductors are visually prominent
features that can contrast with and detract from the aesthetic beauty of most non-industrial
landscapes. Using Bureau of Land Management terminology (BLM 1986-TN6403), these
features can have “moderate” contrast with most natural landscapes. In certain cases, larger
steel-lattice transmission towers or tall steel poles may have “strong” contrast relative to some
natural landscapes.

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However, overhead electric lines, including overhead transmission lines carried on various types
of towers and poles, are a common feature in all but the most pristine of landscapes. In many
landscapes, new transmission lines may be routed to follow existing transmission line ROWs
and thereby avoid introducing such structures to pristine areas. Overhead electric lines on the
sides of roadways are a common visual occurrence expected by most drivers. The clearing of
new ROWs across forested landscapes can create a visually noticeable notch or strip that
breaks the lines of the forest canopy and can be visible from substantial distances, but the
limited length of new ROWs assumed under the PPE limits the extent of any such visual effects.

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The NRC staff has determined that visual impacts from building transmission lines are a
Category 1 issue. The staff relied on the following PPE and SPE values and assumptions to
reach this conclusion:

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

• No transmission line structures (poles or towers) would be over 100 ft in height.

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• The new offsite ROWs would not be situated closer than 1 mi to existing residential areas or
sensitive land uses such as Federal, State, or local parks; wildlife refuges; conservation
lands; Wild and Scenic Rivers; or Natural Heritage Rivers.

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• Any proposed new structures on offsite ROWs would not be visible from Federal or State
parks or wilderness areas designated as Class 1 under Section 162 of the Clean Air Act
(42 U.S.C. § 7472; TN6954); or as a Wild and Scenic River, a Natural Heritage River, or a
river of similar State designation.

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If the PPE and SPE values and assumptions are met, the applicant does not need to submit
visual simulations (such as an artistic rendering) or other projections of visual effects. The
generic analysis can be relied on without conducting any mitigation measures, but possible
mitigation measures to consider might include preserving or establishing tree screens at road
crossings or along the edges of ROWs, or painting steel towers or poles brown or dark green.

3.2.2.2

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The NRC staff identified one environmental issue related to visual resources for operation of a
nuclear reactor:

Environmental Consequences of Operation

• visual impacts during operations.

3.2.2.2.1 Visual Impacts During Operations

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Once structures are built, whether onsite or offsite, they are established features of the
landscape. Operation of the structures for their intended purpose once built does not
substantially alter their appearance. If there is a need during the operational life to refurbish
structures or build new support structures on the site, those changes would most likely not
substantially contrast with the already-developed industrial appearance of the site. Operating
cooling towers release visible fog-like plumes, but any such plumes from mechanical draft
cooling towers meeting the values and assumptions in Section 3.2.1 would likely only be visible
from areas close to the site. A nuclear reactor that meets the values and assumptions would not
include the tall hyperbolic natural draft cooling towers whose plumes can be visible from
substantial distances. Section 3.5.2.2.4 analyzes the potential for drift from cooling towers from
nuclear reactors to injure vegetation and concludes that possible effects are localized to the
immediate location of the cooling towers and would be minimal. The staff has determined that
visual impacts from building transmission lines are a Category 1 issue. The staff relied on the
following PPE and SPE values and assumptions to reach this conclusion:

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• The maximum proposed building and structure height would be no more than 50 ft, except
that the maximum height would be 200 ft for proposed METs and 100 ft for proposed
transmission line poles/towers and proposed mechanical draft cooling towers.

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• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in
height; and equipped with drift eliminators.

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• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).

3.3

3.3.1

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Meteorology and Air Quality
Baseline Conditions and PPE/SPE Values and Assumptions

Baseline conditions influencing potential air quality impacts associated with construction and
operation of a new nuclear reactor include climatology, regional meteorology, atmospheric
stability, the potential for severe weather events, and regional air quality. The atmospheric
processes that occur as a result of these baseline conditions determine the transport of routine
air emissions during construction and routine air emissions or accidental releases during
operation, and their effects on regional air quality. Impacts on regional air quality may result not
only from construction and operation at the plant site but also from construction and operations
at offsite land, which could include construction of intake and discharge structures and
transmission lines, pipelines, or heavy-haul roads. Activities that could potentially cause air
emissions include the following:

• land clearing and material processing, handling, and removal

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• excavation for structures, utilities, access roads and other infrastructure, including
transmission lines

• material replacement (e.g., subsurface preparation and concrete pouring and paving)

• driving piles and erecting structures

• construction machinery operation and maintenance

• truck deliveries of reactor modules, supplies, and materials

• soil transport and temporary stockpiling

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• workforce vehicle use during daily commuting to and around the site and during refueling
outages

• periodic testing of standby power generators and other support equipment

• operation of cooling towers and auxiliary systems

• operation of transmission lines

• refurbishments activities.

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In developing the values and assumptions in the PPE and SPE pertaining to air quality, the staff
relied upon the information and analyses contained in multiple new reactor EISs prepared since
2005, the License Renewal GEIS (NRC 2024-TN10161), and common elements of State and
local regulations. Some values and assumptions made in this section of the GEIS involve
parameters and values that are developed based on previous staff environmental reviews or are
the subject of Federal and State regulations and some have been appropriately scaled down to
account for the size and technology differences between large LWRs potentially smaller new
nuclear reactors. In every case, the staff has selected a value or parameter that will ensure a
minimal impact on local meteorology and air quality from construction and operation of a nuclear
reactor after considering all available information and leveraging professional judgment and
expertise.

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7
8
9
10
11
12
13
14
15
16
17
18
19
20

The PPE and SPE values relevant to air quality assume that the proposed plant site would be
no larger than 100 ac, within which site disturbance would affect no more than 30 ac of land
permanently and no more than 20 ac of additional land temporarily, and offsite ROWs
fortransmission lines, pipelines, or access roads would be no longer than 1 mi; however, these
values and assumptions allow for unlimited additional mileage for linear features built within
existing ROWs or directly adjacent to existing ROWs or public highways. The staff has
concluded that the values stated above used for the land use analysis (as discussed in
Section 3.1) will also apply for the analysis of air quality for determining impacts during building
activities. The PPE and SPE values assume the construction and operation workforce traffic
would not change the level of service (LOS) determination for local road systems, which is
discussed in Section 3.12. The staff has concluded that this PPE/SPE value used for
socioeconomics would also apply for the analysis of air quality for determining impacts from
traffic during building and operation. The PPE and SPE values assume plant cooling would be
accomplished by mechanical draft cooling towers, if needed, which are equipped with drift
eliminators, and are 100 ft in height or less, and the makeup water would be fresh (with a
salinity less than 1 ppt). These values are based on previous license renewal and new reactor
environmental reviews, as discussed in Section 3.5, and will be used to determine the air quality
impacts from the operation of cooling towers. Lastly, for plants using cooling towers, the air
quality section also relies on an assumption that there are no existing residential areas within
0.5 mi of site. This assumption is based on previous new reactor reviews analyses.

21
22
23
24
25
26

New reactor siting also includes consideration of mandatory Class I Federal areas where
visibility is an important value (40 CFR Part 81-TN7226). Although there is little likelihood that
activities at a nuclear reactor site could adversely affect air quality and air quality-related values
(e.g., visibility or acid deposition) in Class I areas, the PPE and SPE assumes that completed
structures would not be located within 1 mi of areas designated as Class I under Section 162 of
the Clean Air Act (42 U.S.C. § 7472-TN6954).

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31
32
33
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35
36
37
38

Air quality is generally measured by the amount of pollution present in the atmosphere. The
U.S. Environmental Protection Agency (EPA) has set National Ambient Air Quality Standards
(NAAQSs) for six criteria pollutants, including sulfur dioxide, nitrogen dioxide, carbon monoxide
(CO), ozone, particulate matter with a mean aerodynamic diameter of 10 μm or less (PM10),
particulate matter with a mean aerodynamic diameter of 2.5 μm or less (PM 2.5), and lead.
Primary NAAQSs specify maximum ambient (outdoor air) concentration levels of the criteria
pollutants with the aim of protecting public health with an adequate margin of safety. Secondary
NAAQSs specify maximum concentration levels with the aim of protecting public welfare. States
can have their own State Ambient Air Quality Standards. State Ambient Air Quality Standards
must be at least as stringent as the NAAQSs and can include standards for additional
pollutants. If a State has no standard corresponding to one of the NAAQSs, the NAAQSs apply
(40 CFR Part 50-TN1089).

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46
47

An area where criteria air pollutants are within NAAQS levels is referred to as an attainment
area, and an area where criteria air pollutants exceed NAAQS levels is called a nonattainment
area (40 CFR Part 81-TN7226). In some cases, the EPA is not able to determine an area’s
status after evaluating the available information and those areas are designated as
“unclassifiable” (EPA 2020-TN6772). Previous nonattainment areas where air quality has been
improved to meet the NAAQSs are redesignated maintenance areas and are subject to an air
quality maintenance plan. Locations of EPA-Designated Nonattainment and Maintenance Areas
for each criteria pollutant, as of April 30, 2024, are available at
https://www3.epa.gov/airquality/greenbook/ancl.html (EPA 2024-TN10122).

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3
4
5
6
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12
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16
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23

If a proposed project is in a nonattainment or maintenance area, the General Conformity Rule
(40 CFR Part 93-TN2495) ensures that Federal actions comply with the NAAQSs (EPA 2020TN6773). In accordance with Section 176(c) of the Clean Air Act (42 U.S.C. § 7506-TN4856)
and the General Conformity Rule, the NRC must analyze the proposed permit action for
conformity applicability; therefore, the NRC must demonstrate that the air emissions associated
with activities within its authority would conform to the appropriate state implementation plans,
which are developed to improve or maintain air quality in designated nonattainment and
maintenance areas. The EPA has established de minimis levels for each criteria pollutant
(EPA 2020-TN6774). If a project is located in a nonattainment or maintenance area and the
project’s emissions are estimated to exceed the de minimis levels for any criteria pollutant as
demonstrated in an applicability analysis, a conformity determination must be performed. When
the total direct and indirect emissions from the proposed plant are below the de minimis levels,
the project/action would not be subject to a conformity determination (EPA 2020-TN6773). The
first step in determining whether an action conforms is to perform an applicability analysis to
determine whether the action is exempt or has total net direct and indirect emissions below the
de minimis levels. The applicability analysis must be documented. If the applicability analysis
demonstrates that the total net direct and indirect emissions exceed the de minimis levels, the
agency must prepare a written conformity determination for each pollutant for which the
emissions caused by a proposed Federal action would exceed the de minimis levels. A
conformity determination, if needed, must be completed before the action is taken. The PPE
and SPE assume the proposed plant could be located in either attainment, nonattainment, or
maintenance areas, but if located in a nonattainment or maintenance area the criteria
pollutant(s) emitted would be less than the de minimis levels set by the EPA or State.

24
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26
27

Some plant equipment such as diesel generators and cooling towers may emit some hazardous
air pollutants (HAPs) during operation. The EPA coordinates with State, local, and Tribal
governments to reduce the air emissions of almost 200 toxic air pollutants to the environment.
The PPE assumes that these emissions are within limits established by the EPA or State.

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34
35

CEQ has recognized that climate change is a fundamental environmental issue within NEPA’s
purview (88 FR 1196). In accordance with Executive Order 13990, CEQ rescinded draft
guidance entitled, “Draft National Environmental Policy Act Guidance on Consideration of
Greenhouse Gas Emissions,” and on January 9, 2023 issued interim guidance entitled,
“National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions
and Climate Change,” (88 FR 1196) to assist agencies in conducting greenhouse gas (GHG)
and climate change effects analyses on their proposed actions. At the time of publication of this
GEIS, CEQ had not finalized the interim guidance.

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39
40
41
42
43
44
45

Gases found in the Earth’s atmosphere that trap heat and play a role in the Earth’s climate are
collectively termed GHGs. GHGs include carbon dioxide (CO 2); methane (CH4); nitrous oxide
(N2O); water vapor; and fluorinated gases, such as hydrofluorocarbons, perfluorocarbons, and
sulfur hexafluoride. Climate change research indicates that the cause of the Earth’s warming
over the last 50 years is the buildup of GHGs in the atmosphere, resulting from human activities
(IPCC 2023-TN10123). The EPA has determined that GHGs “may reasonably be anticipated
both to endanger public health and to endanger public welfare” (74 FR 66496-TN245). Climate
change is a subject of national and international interest because of how it changes the affected
environment. Commission Order CLI-09-21 (NRC 2009-TN6406) provides the current direction
to the NRC staff to include the consideration of the impacts of the emissions of CO 2 and other

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1
2
3
4
5
6
7

GHGs that drive climate change in its environmental reviews for major licensing actions. 2
Estimates of GHG emissions from a reference 1,000 megawatts electrical (MWe) reactor were
developed using the approach in Interim Staff Guidance COL/ESP-ISG-026 (NRC 2014TN3767), Interim Staff Guidance on Environmental Issues Associated with New Reactors, and
also considered the Council on Environmental Quality’s (CEQ’s) 2016 final guidance on
considering GHGs emissions and effects of climate changes in NEPA reviews (NRC 2014TN3768; CEQ 2016-TN4732) and are presented in Appendix H of this GEIS.

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26

GHGs are emitted from equipment and vehicles used during building, operation, the uranium
fuel cycle, transportation of fuel and waste, and decommissioning including extended SAFe
STORage (SAFSTOR). Appendix H estimates GHG emissions for life-cycle phases for a
reference 1,000 MWe reactor with an 80 percent capacity factor. The calculation of GHG
emissions for a new nuclear reactor assumes two 1,000 MW(e) nuclear reactors could be
installed on the same site, based on previous applications for sites with two or more new LWRs
(NRC 2015-TN6438, NRC 2016-TN6434, NRC 2019-TN6136). GHG emission estimates for
building, operation, decommissioning, including extended SAFSTOR, for a two-unit nuclear
plant would be based on the plant’s physical size, and the estimates for these stages are
assumed to be twice the value of the reference 1,000 MWe reactor emission estimates in
Appendix H. However, GHG emission estimates for the uranium fuel cycle and transportation of
fuel and waste would be based on the anticipated efficiency of the proposed plant. For example,
the Final EIS for Turkey Point Units 6 and 7 scaled GHG emissions from the fuel cycle upward
by a factor of 2.6, and the Final EIS for the Public Service Enterprise Group (PSEG) scaled
GHG emissions from the fuel cycle upward by a factor of 3, based on plant efficiencies greater
than the 80 percent assumption in Appendix H (NRC 2016-TN6434, NRC 2015-TN6438). To
provide bounding values, the estimates for GHG emissions for uranium fuel cycle activities and
fuel and waste transport associated with a new nuclear reactor in this GEIS were calculated
using three times the values for the reference 1,000 MWe reactor in Appendix H.

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29
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31

Based on the Interim Staff Guidance COL/ESP-ISG-026 approach used in several new reactor
EISs, the reference 1,000 MWe reactor emissions described in Appendix H, and the scaling
factors discussed above, the PPE/SPE value for GHGs emitted by equipment and vehicles
during the 97-year GHG life-cycle period for a nuclear reactor would be equal to or less than
2,534,000 metric tonnes (MT) of CO2(e),3 as shown in Table 3-1.

3.3.2

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Most air quality impacts from new nuclear reactors would take place during the building of the
project. Impacts would occur primarily during site preparation and the building of facility
components such as the nuclear island and facilities such as cooling towers, administration
buildings, parking lots, switchyards, and any onsite and offsite pipelines, access roads, and
transmission lines. Air emissions from vehicles and stationary support equipment, such as
auxiliary equipment, would occur during operation and would increase periodically during
equipment testing and during refueling outages, depending on the plant design. Air emissions
also result from operation of the cooling towers. Small amounts of ozone and NOx are produced
by transmission lines during operation.

Air Quality Impacts

The Commission stated that “the Staff’s analysis for reactor applications should encompass emissions from the
uranium fuel cycle as well as from construction and operation of the facility to be licensed.” (CLI-09-21, at 6)
3
A measure to compare the emissions from various GHGs on the basis of their global warming potential (GWP),
defined as the ratio of heat trapped by one unit mass of the GHG to that of one unit mass of CO 2 over a specific time
period.
2

3-18

Table 3-1

Plant Parameter Envelope Values for Greenhouse Gas Emissions

Source
Construction Equipment(a)
Construction Workforce(a)
Plant Operations(b)
Operations Workforce(b)
Uranium Fuel Cycle(b)
Fuel and Waste Transportation(b)
Decommissioning Equipment(c)
Decommissioning Workforce(c)
SAFSTOR Workforce
TOTAL(d)
(a)
(b)
(c)
(d)

Total
Emissions
(reference
1,000 MW
Reactor)
(MT CO2(e))
39,000
43,000
181,000
136,000
540,000
14,000
19,000
8,000
10,000
990,000

Activity
Duration
(yr)
7
7
40
40
40
40
10
10
40
97

Scaling
Factor
2
2
2
2
3
3
2
2
2
-

PPE Emission
Values
(Two 1,000 MW
Reactors)
(MT CO2(e))
78,000
86,000
362,000
272,000
1,620,000
42,000
38,000
16,000
20,000
2,534,000

Activities are assumed to occur over the same time frame.
Activities are assumed to occur over the same time frame.
Activities are assumed to occur over the same time frame.
Results are rounded to the nearest 1,000 MT CO 2(e).

2
3
4
5
6
7
8
9
10
11
12

The NRC staff evaluated the total GHG emissions for a nuclear reactor. Equipment and vehicles
used during building, operation, uranium fuel cycle, transportation of fuel and waste, and
decommissioning activities would emit a total of 2,534,000 MT of CO2(e) over the assumed
97-year GHG life-cycle of the plant (see Table 3-1). For comparison, in 2022, total gross annual
U.S. GHG emissions were 6,343.2 million metric tons (MMT) of CO 2(e), of which 5,199.8 MMT
CO2(e) were from the energy sector (EPA 2024-TN10121). Assuming this annual rate for energy
sector emissions is constant over the same 97-year time span as the operation of the plant, the
total emissions from the U.S. energy sector would be 525 billion metric tons (BMT) CO 2(e).
Based on these values and assumptions, estimated annual GHGs emissions from the plant lifecycle would be about 0.0005 percent of GHG emissions from the U.S. energy sector over the
same period.

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15
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18

The staff has determined that the contribution of GHG emissions from total plant life-cycle
activities to national emissions is a Category 1 issue. The staff concludes that, as long as the
PPE assumption associated with GHG emissions is met, the GHG impacts from building,
operating, conducting the fuel cycle, transporting fuel and waste, and decommissioning of a
nuclear reactor can be generically determined to be SMALL. The staff relied on the following
PPE assumption to reach this conclusion:

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25
26

• GHGs emitted by equipment and vehicles during the 97-year reactor GHG life-cycle period
would be equal to or less than 2,534,000 MT of CO2(e). Appendix H of this GEIS contains
the staff’s methodology for developing this value, which includes emissions from
construction, operation, and decommissioning. As long as this total value is met, the impacts
for the life-cycle of the project and the individual phases of the project are determined to be
SMALL.
The generic analysis can be relied on without applying any mitigation measures. GHG impacts
associated with building and operation (including the fuel cycle and transportation of fuel and

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2

waste) are discussed below. Air quality impacts including GHG emissions for decommissioning
are evaluated in Section 3.16 of this GEIS.

3.3.2.1

Environmental Consequences of Construction

4
5
6
7
8
9
10

The staff’s evaluation of impacts on air quality during building activities focused on emissions
from construction equipment and vehicles, and fugitive dust generation. Major activities include
earthmoving, open burning, placement of land fill, concrete batch plant operation, facility
construction, operation of temporary boilers, and emission of vehicular exhaust. Emissions from
these activities would include PM, CO, NOx, sulfur dioxide, and volatile organic compounds
(VOCs). Building activities at the site of a new nuclear reactor would result in temporary impacts
on local air quality.

The NRC staff identified two air quality issues for analysis of construction of a nuclear reactor:

12
13

• emissions of criteria pollutants and fugitive dust to the atmosphere in relation to regional air
quality conditions and NAAQSs for criteria pollutants; and

• emissions of GHGs.

3.3.2.1.1 Emissions of Criteria Pollutants and Dust during Construction

16
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18
19
20
21
22
23
24
25
26
27

Equipment and vehicle emissions from building activities including passenger cars and light duty
trucks of the construction workforce, delivery trucks, and heavy equipment (e.g., excavators,
bulldozers, heavy-haul trucks, cranes) would contain CO, NOx, VOCs, and oxides of sulfur
(SOx) to a lesser extent. Fugitive dust (such as PM10 and PM2.5) would be generated during
windy periods, earthmoving, concrete batch plant operation, and movement of vehicular traffic
over recently disturbed or cleared areas or unpaved roads. Painting, coating, and similar
operations would generate emissions of VOCs. Typically, the construction workforce would be
divided into two or three shifts and the increased traffic would be distributed over the day, with
periodic and short-term increases at shift changes. Construction activities are typically subject to
air permits under State and Federal laws that address the impact of air emissions on any local
sensitive receptors. Air emission mitigation measures that may be used to reduce potential
impacts include the following:

28
29
30

• phasing activities and equipment use
• minimizing the idling time of vehicles
• using properly maintained equipment in compliance with applicable regulations

31
32
33
34
35
36

•
•
•
•

37
38
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41

minimizing speeds on unpaved roads
watering unpaved roads and exposed areas
minimizing soil storage piles
locating stationary equipment (e.g., generators, temporary boilers, and compressors) away
from sensitive receptors
• minimizing dust-generating activities during high winds.
Emissions of fugitive dust and construction equipment engine exhaust are generally limited in
duration, infrequent, mostly localized to the project area, and would vary based on the level and
duration of a specific activity throughout the building phase of the facility. The PPE/SPE
assumes the total site size is 100 ac or less, the permanent disturbed vegetated areas is 30 ac
or less, and the additional vegetated area disturbed by temporary activities is 20 ac or less, and

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9

that new offsite ROWs for transmission lines, pipelines, or access roads would be no longer
than 1 mi and have a maximum ROW width of 100 ft. The air quality impacts are therefore
expected to be temporary and limited to the area within 6 mi of the plant construction site. The
PPE/SPE assumes the plant is located in an attainment area or that criteria pollutants emitted
from vehicles and standby power equipment during construction are less than Clean Air Act de
minimis levels set by the EPA and that the project/action is located in a nonattainment or
maintenance area and, therefore, would not be subject to a conformity determination. The
PPE/SPE assumes the site is not located within 1 mi of a mandatory Class I Federal area where
visibility is an important value.

10
11
12
13
14
15
16

Some communities located near the construction site may experience increases in traffic and
associated increases in the amount of particulate and gaseous emissions. The impact of
emissions from additional workforce and other construction traffic would be localized and
temporary and have little impact on the regional air quality (NRC 2021-TN7037). Under the PPE
and SPE assumption that the LOS determination associated with anticipated peak construction
would not change, traffic bottlenecks that could significantly increase localized emissions from
idling vehicles are not expected to occur.

17
18
19
20
21

The staff has determined that emissions of criteria pollutants during construction of a nuclear
reactor are a Category 1 issue. The staff concludes that as long as the applicable PPE and SPE
values and assumptions are met, the air quality impacts from building a nuclear reactor can be
generically determined to be SMALL. The staff relied on the following PPE values and
assumptions to reach this conclusion:

• The site size is 100 ac or less.

23
24

• The permanent footprint of disturbance is 30 ac or less of vegetated lands and the
temporary footprint of disturbance is an additional 20 ac or less of vegetated land.

25
26

• New offsite ROWs for transmission lines, pipelines, or access roads would be no longer than
1 mi and have a maximum ROW width of 100 ft.

27
28
29

• Criteria pollutants emitted from vehicles and standby power equipment during construction
are less than Clean Air Act de minimis levels set by the EPA if the site is located in a
nonattainment or maintenance area, or the site is located in an attainment area.

30
31

• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an
important value.

• The LOS determination for affected roadways does not change.

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34

• Mitigation necessary to rely on the generic analysis includes implementation of BMPs for
dust control.

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36

• Compliance with air permits under State and Federal laws that address the impact of air
emissions during construction.

3.3.2.1.2 GHG Emissions during Construction

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43

Equipment and vehicles used during building activities, including construction worker vehicles
and delivery trucks, would emit GHGs, principally CO 2. Combining the PPE values for GHG
emissions for these two stages listed in Table 3-1 above, 164,000 MT CO2(e) would be emitted
during a 7-year construction period of two 1,000 MW reactors, or less than 24,000 MT/yr CO2(e)
on average. For comparison, in 2022, total gross annual GHG emissions in the United States
were 6,343.2 MMT of CO2(e), of which 5,199.8 MMT CO2(e) was from the energy sector (EPA

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2

2024-TN10121). Estimated annual GHG emissions from equipment used during building
activities are about 0.00045 percent of the 2022 GHG emissions from the U.S. energy sector.

3
4
5
6
7
8

As noted in Section 3.3.2.1.2 above, the NRC staff has determined that the contribution of plant
life-cycle GHG emissions to national emissions is a Category 1 issue. The NRC staff concludes
that, as long as the PPE and SPE assumptions associated with the life-cycle GHG emissions
are met, the GHG impacts from building a nuclear reactor can also be generically determined to
be SMALL. The staff relied on the following PPE values and assumptions to reach this
conclusion:

9
10
11
12
13
14

• GHGs emitted by equipment and vehicles during the 97 year reactor GHG life-cycle period
would be equal to or less than 2,534,000 MT of CO2(e). Appendix H of this GEIS contains
the staff’s methodology for developing this value, which includes emissions from
construction, operation, and decommissioning. As long as this total value is met, the impacts
for the life-cycle of the project and the individual phases of the project are determined to be
SMALL.

The generic analysis can be relied on without applying any mitigation measures.

3.3.2.2

The NRC staff identified four air quality issues for analysis of the operation of a nuclear reactor:

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19

• emissions of criteria and HAPs to the atmosphere during operation activities in relation to
regional air quality conditions and thresholds for NAAQSs for criteria pollutants and HAPs;

20
21
22

• cooling-system impacts such as ground-level fogging/icing, plume shadowing, drift
deposition from dissolved salts and chemicals found in the cooling water, and ground-level
temperature and humidity increases;

• emissions to the atmosphere of ozone and NOx from transmission line operation; and

• GHG emissions during operations.

Environmental Consequences of Operation

25
26

These air quality impacts would be expected to continue during the operational life of the
reactor.

3.3.2.2.1 Emissions of Criteria and Hazardous Air Pollutants during Operation

28
29
30
31
32

The principal air emission sources for criteria pollutants would be auxiliary equipment, such as
boilers for heating and startup, engine-driven emergency equipment, emergency power supply
system diesel generators and/or gas turbines, depending on the plant design, and refurbishment
activities. Emissions would include NOx, CO, SOx, CO 2, CH4, N2O, hydrocarbons in the form of
VOCs, and PM2.5 and PM10.

33
34
35
36
37
38
39
40

Impacts on air quality during normal plant operations can result from operations of fossil-fuelfired equipment needed for various plant functions, although these types of operations may be
reduced, limited, or not present for smaller reactor designs. Each licensed plant typically
employs emergency diesel generators for use as a backup power source. Emergency
generators would be used on an infrequent basis and therefore pollutants discharged
(e.g., particulates, SOx, CO, hydrocarbons, and NOx) would be released infrequently.
Emergency diesel generators and fire pumps typically require State or local operating permits
for routine (typically monthly) testing. These monthly tests have several test burns of various

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3
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5
6
7
8
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12

durations (e.g., 1 to several hours). In addition to these maintenance tests, longer-running
endurance tests are typically conducted at each plant. Each generator is typically tested for
24 hours on a staggered test schedule (e.g., once every refueling outage) (NRC 2024TN10161). Plants with nonelectric fire pumps, typically also diesel-fired, usually employ test
protocols identical or similar to those used for emergency generators. Many State air pollution
regulations provide exemptions for air pollution sources that are not routinely operated, which
can be defined as sources that have insignificant activity, meeting specified operating criteria
(e.g., so many hours of continuous operation over specified periods or so many hours of
operation per year) (NRC 2024-TN10161). In addition to the emergency diesel generators,
fossil-fueled (i.e., diesel-, oil-, or natural-gas-fired) boilers can be used primarily for evaporator
heating, plant space heating, and/or feed water purification. Again, depending on the simplicity
of the reactor design, this equipment may be reduced or eliminated.

13
14
15
16
17
18
19
20
21
22
23

Air emission sources associated with nuclear power plant operation would be managed in
accordance with Federal, State, and local air quality control laws and regulations. A new plant at
any U.S. site would comply with all regulatory requirements of the Clean Air Act, as well as any
relevant State requirements to minimize impacts on State and regional air quality. When an
applicant selects a project design, modeling, as required, will be conducted to demonstrate the
project emissions will not result in exceedances of the NAAQS. The evaluation will include a
determination of whether the project is in an attainment area for all NAAQS criteria pollutants
(Clean Air Act, Part D-TN6972), and whether the proposed project is subject to a Nonattainment
New Source Review (EPA 2016-TN6970). A PPE for this GEIS assumes that all operational
emissions of criteria pollutants are below de minimis levels for NAAQSs if the project/action is
located in a nonattainment or maintenance area.

24
25
26
27
28
29
30
31

Operations-related traffic would also result in vehicular air emissions. Some communities
located near the construction site may experience increases in traffic and associated increases
in the amount of particulate and gaseous emissions. The impact of emissions from additional
workforce traffic would be localized and have little impact on the regional air quality (NRC 2021TN7037). Nominal localized increases in emissions would occur as a result of the increased
numbers of cars, trucks, and delivery vehicles that would travel to and from the plant site.
Emission impacts for operation assume that LOS values can be maintained with the increased
traffic volumes.

32
33
34
35
36
37

In addition to criteria pollutants, fuel oil for the diesel generators is a source of HAPs. To be
considered a major source of HAPs by EPA, a facility must have the potential to emit 10 T/yr of
an individual HAP or 25 T/yr or more total for all HAPs (Clean Air Act; 42 U.S.C.
§§ 7401 et seq.; TN1141). Because diesel generators operate on a limited basis (typically
monthly), the staff does not expect that HAPs associated with a nuclear reactor would meet the
10 tons/yr threshold. The PPE assumes that HAPs emissions will be within regulatory limits.

38
39
40
41
42
43

The staff has determined that air quality during operation of a nuclear reactor is a Category 1
issue. The potential impact from emergency generators and boilers on air quality, given the
infrequency and short duration of maintenance testing, would not be an air quality concern. The
staff concludes that air quality impacts from operating a nuclear reactor can be generically
determined to be SMALL. The staff relied on the following PPE values and assumptions to
reach this conclusion:

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46

3-23

1
2

• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an
important value.

• The LOS determination for affected roadways does not change.

• The generic analysis can be relied on without applying any mitigation measures.

5
6

• Compliance with air permits under State and Federal laws that address the impact of air
emissions.

• HAP emissions will be within regulatory limits.

3.3.2.2.2 GHG Emissions during Operation

9
10
11
12
13
14
15
16
17

Equipment and vehicles used during plant operations, the uranium fuel cycle, and fuel and
waste transport would emit GHGs, principally CO 2. Combining the PPE values for GHG
emissions for these stages listed in Section 3.3.1 above, 2,296,000 MT would be emitted during
a 40-year operation period for two 1,000 MW reactors, or about 57,400 MT/yr on average. As
with construction activities, these emissions can be compared with 2022 total gross annual U.S.
energy sector emissions of 5,199.8 MMT CO 2(e) (EPA 2024-TN10121). Estimated annual
GHGs emissions from equipment used during operation, the uranium fuel cycle, and
transportation of fuel and waste activities are about 0.001 percent of the 2019 GHG emissions
from the U.S. energy sector.

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As noted in Section 3.3.2.2.2 above, the staff has determined that the contribution of plant lifecycle GHG emissions to national emissions is a Category 1 issue. The staff concludes that, as
long as the PPE assumption associated with GHG emissions is met, the GHG impacts from
operating a nuclear reactor can also be generically determined to be SMALL. The staff relied on
the following PPE values and assumptions to reach this conclusion:

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The generic analysis can be relied on without applying any mitigation measures.

3.3.2.2.3 Cooling-System Emissions

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The primary impacts of operating a new nuclear power plant on local meteorology would be
from releases to the environment of heat and moisture from the primary cooling system. Cooling
towers, if used, would remove excess heat by evaporating water. Upon exiting the tower, water
vapor would mix with the surrounding air, and this process would generally lead to condensation
and formation of a visible plume, which would have aesthetic impacts. Cooling towers would
also produce drift. Drift is composed of small water droplets that are carried out of the cooling
tower. These droplets evaporate, leaving particles that contain residual salts and chemicals
from the cooling water. Drift from mechanical draft cooling towers is deposited near the cooling
tower, and drift from natural draft towers is deposited farther downwind (NRC 2024-TN10161).
Wet cooling towers at existing nuclear power plants generally have drift eliminators to reduce
drift (NRC 2024-TN10161). Other meteorological and atmospheric impacts from cooling towers
include ground-level fogging/icing, plume shadowing, and ground-level temperature and

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humidity increases. In addition, plumes from the cooling towers could interact cumulatively with
emissions from other sources on the site.

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The PPE includes an assumption of a maximum height of 100 ft for mechanical draft cooling
towers that have drift eliminators. The PPE also assumes that the site is not located within 1 mi
of a mandatory Class I Federal area where visibility is an important value. The SPE assumes
there will be no existing residential areas within 0.5 mi of the site.

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The License Renewal GEIS (NRC 2024-TN10161) and SEISs for individual plant relicensing
evaluated the impact of the continued operation of cooling towers, including natural draft cooling
towers, at existing power plants for an additional 20 years and found the impacts to be SMALL.
For these license renewal reactor EISs, most of the impacts occurred within 1 mi of the cooling
towers. The staff evaluated the impact of continued operation of cooling towers, including
natural draft cooling towers, at existing power plants for an additional 20 years and found the
impacts to be SMALL. In the License Renewal GEIS (NRC 2024-TN10161) the staff reviewed
the distances and impacts from deposition of salt drift from nuclear power plants, which states
the “...measurements indicate that, beyond about 1.5 km (1 mi) from nuclear plant cooling
towers, salt deposition is not significantly above natural background levels.” In addition, the
NRC staff reviewed the recent new reactor EIS reviews for cooling-tower impacts and the
impacts were found to be SMALL for ground-level fogging/icing, plume shadowing, drift
deposition from dissolved salts and chemicals found in the cooling water, and ground-level
temperature and humidity increases (NRC 2021-TN7037). For these new reactor EISs, most of
the impacts occurred within 1 mi of the cooling towers except for the longest plumes which
occurred typically within 5 mi of the cooling towers, but these plume lengths were infrequent,
occurring a small percentage of the time during certain times of the year. Icing impacts were
infrequent and in more southern areas of the U.S. were not likely to occur (i.e., Florida, Texas,
South Carolina) as compared to more northern areas of the United States.

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In addition to emissions of criteria pollutants, releases of HAP could be expected from chemical
additives used in the cooling-tower water. Some examples of these chemical additives are
sodium hypochlorite (NaOCl), sodium hydroxide (NaOH), hydroxyethylidine diphosphonic acid
(HEDP), and petroleum distillate. Chemical additives added to cooling-tower water are within
State regulatory limits or would be within the releases of HAPs listed in Section 112 of the Clean
Air Act (42 U.S.C. § 7412-TN7014). The PPE assumes that the emissions of HAPs from the
cooling tower will meet the regulatory limits set by EPA or the State.

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The staff has determined that air quality during operation of cooling towers associated with a
nuclear reactor is a Category 1 issue. The staff concludes that air quality impacts from operating
cooling towers associated with a nuclear reactor can be generically determined to be SMALL.
The staff relied on the following PPE values and assumptions to reach this conclusion:

• If needed, cooling towers would be mechanical draft, not natural draft.

• Cooling towers would be equipped with drift eliminators.

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• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an
important value.

• Mechanical draft cooling towers would be less than 100 ft tall.

• Makeup water would be fresh (with a salinity less than 1 ppt).

• Operation of cooling towers is assumed to be subject to State permitting requirements.

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• HAP emissions would be within regulatory limits.

• No existing residential areas within 0.5 mi of the site.

3.3.2.2.4 Emissions of Ozone and NOx during Transmission Line Operation

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Small amounts of ozone and even smaller amounts of NOx are produced by transmission lines
and associated equipment. The impacts of existing transmission lines on air quality are
addressed in the License Renewal GEIS (NRC 2024-TN10161). The staff found the production
of ozone and NOx to be insignificant for 765 kilovolts (kV) transmission lines (the largest lines in
operation) and for a prototype 1,200 kV transmission line (NRC 2024-TN10161). In addition, it
was determined that potential mitigation measures, such as burying transmission lines, would
be very costly and would not be warranted.

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The staff has determined that air quality during operation of transmission lines is a Category 1
issue. The staff concludes that based on the License Renewal GEIS (NRC 2024-TN10161) and
more recent new reactor EIS findings, impacts from emissions of ozone and NOx can be
generically determined to be SMALL without relying on mitigation. The staff relied on the
following PPE value to reach this conclusion:

• The transmission line voltage would be no higher than 1,200 kV.

3.4

Water Resources

3.4.1

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Water resources comprise surface water bodies (e.g., rivers, streams, lakes, ponds, estuaries,
oceans, and manufactured reservoirs) and groundwater aquifers (including unconfined, water
table aquifers, deeper confined aquifers, and perched saturated zones). Exchange between
surface water bodies and groundwater systems is common (e.g., groundwater discharge to, or
recharge from, abovementioned surface water bodies). Water may be used for many purposes
including public and domestic supplies, industrial (including cooling) processes, building-related
activities, agriculture, hydropower production, recreation, and general ecosystems support. An
assessment of baseline conditions for water resources includes a description of the surface
water bodies and groundwater aquifers potentially affected by the building and operation of a
proposed plant, the existing and planned uses of the affected water bodies, trends in water
quality, and any regulatory restrictions on water use or on discharges affecting water quality.

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Nuclear power plants use water during both construction and operation. However, impacts on
water resources are typically greatest during plant operations, which require water over an
operating period that could last for 40 or more years. In the current fleet of power plants with
large LWRs, the predominant use for water during operations is for removing excess heat
generated in the reactor by condenser cooling. Some new nuclear reactor designs may not use
water for cooling purposes. If cooling water is not used, then the impacts from the use of cooling
water does not need to be analyzed. In addition to removing heat from the reactor, cooling water
is also provided to the service water system and to the auxiliary cooling-water system. However,
the amount of water used by these systems is small compared to the amount of water typically
required for the condenser cooling system. Nuclear power plants may also require water for
other plant systems (e.g., fire suppression) and for sanitary or potable uses. During operations,
nuclear power plants typically discharge warm water to a receiving water body. This discharge
can contain blowdown from cooling systems, process water from other plant systems, and
sanitary system discharges. Reduction or elimination of water use and discharge will increase

Baseline Conditions and PPE/SPE Values and Assumptions

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the number of potential sites at which a new nuclear reactor may be located and decrease the
potential for impacts on water resources in the vicinity of the corresponding location.

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Construction activities and nuclear power plant operations may contribute to changes in water
quality conditions. Removal of vegetation and construction of buildings, parking lots, and other
impervious surfaces can increase runoff from a site and result in the entrainment of sediments
and pollutants in the runoff that ultimately discharges to nearby water bodies. Building of intake
and discharge structures may temporarily disturb natural water flows similar to dredging or fill
placement in waterways. Water withdrawal for plant use may affect the quality of the
groundwater or surface water source. Discharge of cooling water and other plant wastewaters
introduces chemical constituents of plant operations (e.g., cooling-water treatment chemicals)
and thermal pollution to the receiving water body. In addition, inadvertent chemical spills or
releases that are transported with runoff may contaminate surface water and groundwater
resources.

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During both construction and operation of a nuclear power plant, water from municipal sources
may be needed to support the potable and sanitary needs of plant personnel. The potential
municipal water demand is expected to be relatively small compared to a plant’s cooling-water
needs. However, this water demand may affect the ability of nearby municipal water systems to
meet their planned obligations. Nuclear power plants may also discharge plant effluents (e.g.,
sanitary and sewage discharges) to municipal wastewater systems that may affect the municipal
systems’ ability to meet their planned obligations.

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Applicants seeking to construct and operate a nuclear reactor must obtain and comply with all
applicable permits and authorizations that regulate alterations and limit impacts on the
hydrologic environment. Federal regulations for water quality, use, and withdrawal stem from
the CWA (codified as the Federal Water Pollution Control Act of 1972; 33 U.S.C. §§ 1251
et seq.; TN662).4 Dredging and construction-related activities are regulated by provisions of the
CWA Section 404 (33 U.S.C. § 1344-TN1019) and Section 10 of the Rivers and Harbors
Appropriation Act of 1899 (33 U.S.C. §§ 401 et seq.; TN660). Federal regulations may be
administered through a State permitting program, which may institute more restrictive criteria
based on the unique regional or local environment or environmental issues. In addition, local or
regional water boards or river authorities may require registration, notification, and permitting of
the use of water from rivers, reservoirs, and aquifers. Descriptions of applicable laws,
regulations, and other authorizations are provided in Appendix F.

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For each potential resource impact described in the following sections, the level of information
provided should be related to the amount of use and the degree of anticipated impacts.
Applicants should provide a description of communications with relevant Federal, State,
regional, and local authorities and agencies related to obtaining applicable permits and
authorizations governing water use and quality. Compliance with environmental quality
standards and permit requirements does not satisfy the need for NRC staff to evaluate
environmental impacts. However, any assessment that supports the permit may be considered
as part of the evaluation of environmental impacts. See footnote 3 to 10 CFR 51.71(d) (TN250).

The CWA includes Sections 401 (Water Quality Certification; 33 U.S.C. § 1341-TN4764), 402 (National
Pollutant Discharge Elimination System, or NPDES, permit; 33 U.S.C. § 1342-TN4765), and
Sections 316(a) and 316(b) (for cooling-water discharges and withdrawals, respectively; 33 U.S.C. §
1326-TN4823). Applicable regulations also include U.S. Environmental Protection Agency measures for
spill prevention and response (40 CFR Part 112 [TN1041]).

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Monitoring programs should be developed to identify potential adverse impacts and to formulate
associated water resource mitigation strategies related to operation. Monitoring programs,
which are required as part of Federal and State permits, should include identification of
alternatives or engineering measures that could be implemented to mitigate impacts, if needed.

3.4.1.1

3.4.1.1.1 Surface Water Use

Surface Water Resources

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Operating large LWR nuclear power plants typically withdraw large volumes of surface water to
meet a variety of plant needs related primarily to use in cooling systems. Nuclear reactors could
be either “dry” cooled, “wet” cooled, or use a combination of both (“hybrid”). Dry-cooled systems
use no water and can significantly decrease the total water consumption of a power plant. Wetcooled systems rely on water for cooling and use systems that interface significantly with water
resources. With one exception, the current fleet of operating large LWR nuclear plants rely on
surface water sources for cooling. These sources include flowing water bodies (e.g., stream,
canal, or river) and non-flowing water bodies (e.g., oceans, gulfs, intertidal zones, estuaries,
lakes, ponds, and reservoirs)5 and use a variety of cooling systems. Currently, the Palo Verde
Nuclear Generating Station is the only operating plant that uses treated wastewater for cooling
purposes. Proposed new large LWRs may also plan to withdraw water from a variety of surface
water sources to supply the cooling-water system with makeup water. Once-through systems
are used for most operating units. The remaining units employ closed-cycle systems, which rely
on cooling ponds, lakes, canals, and mechanical and natural draft cooling towers to transfer
waste heat to the atmosphere. Compared to the large LWRs mentioned above, it is anticipated
that smaller nuclear reactors may use cooling technologies that reduce or eliminate reliance on
water for cooling purposes or for reactor shutdown.

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In environmental reviews for large LWRs, the NRC staff evaluates the effects that plant water
use may have on the availability of surface water resources and the impacts of uses and users
of these resources. For this GEIS, the staff developed plant and site parameters for water
demand and available supply to provide guidance for evaluating issues arising from water use
conflicts between the proposed plant and other uses and users. These parameters are
presented and explained in the PPE/SPE table in Appendix G. The total plant water demand
PPE was developed by the NRC staff after considering the bounding value for water
requirements presented in the NRIC PPE report for advanced nuclear reactor designs
(NRIC 2021-TN6940). This NRIC bounding value includes water use by all advanced nuclear
reactor plant systems. The NRC staff increased this value to the nearest 1,000 gpm to derive
the PPE for this GEIS, which specifies that the total plant water demand does not exceed a daily
average of 6,000 gpm. The NRC staff assumed that the total plant water demand accounts for
the maximum amount of water supply required for all plant needs and may include water from
multiple sources.

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Based on this PPE value, the total surface water use by plant systems would be less than or
equal to 6,000 gpm. Because the NRIC PPE report covers a wide range of reactor types and
power outputs, the staff expects that the 6,000 gpm limit would not be overly restrictive of new
5

Flowing and non-flowing water bodies are distinguished primarily based on the mechanism that provides
water availability. Water availability in flowing water bodies (e.g., stream, canal, or river) is primarily
provided by the water body’s discharge rate and storage effects are minor. In non-flowing water bodies
(e.g., oceans, gulfs, intertidal zones, estuaries, lakes, ponds, and reservoirs), water availability is primarily
provided by the volume of stored water.

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reactor designs addressed by this GEIS. This limit also provides staff with confidence that
conclusions reached in this GEIS will be valid given the wide range of site characteristics and
settings to which this GEIS might be applicable.

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The staff separated potential surface water sources into two broad categories in the generic
analysis: (1) flowing surface water bodies (e.g., stream, canal, or river) and (2) non-flowing
surface water bodies. The staff differentiated non-flowing surface water bodies into two
categories that are based on water body size and correspond to the potential for hydrologic and
aquatic impacts from plant water usage at the PPE withdrawal rate discussed above. The
categories are large water bodies (specifically the Great Lakes, the Gulf of Mexico, estuaries,
intertidal zones, and oceans) and smaller water bodies (e.g., inland lakes, ponds, and
reservoirs).

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To minimize the impact on flowing surface water bodies, the SPE specifies that plant
withdrawals from water bodies be limited to no more than 3 percent of the 95 percent
exceedance daily low flow of the source. The staff developed this SPE criterion for water
withdrawal by evaluating the impacts related to plant use of flowing surface water bodies in EISs
for new reactors and the License Renewal GEIS for operating reactors (NRC 1996-TN288, NRC
2024-TN10161). Based on the evaluations provided in these recent EISs and the License
Renewal GEIS, the staff determined that the impacts would be SMALL for withdrawal rates at or
below 3 percent of the water available during low flow conditions. In addition, this SPE value is
bounded by the EPA 316(b) Proportional Flow Limitation (40 CFR 125.84(b)(3)(i) [TN254]),
which specifies that plants not withdraw more than 5 percent of the source water body annual
mean flow. The staff assumed that the 95 percent exceedance daily flow is estimated
accounting for all existing withdrawals and instream flow requirements.

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For large non-flowing surface water bodies, the staff recognize that project-specific conditions
could result in noticeable impacts on water resources at sufficiently large withdrawal rates.
However, water bodies the staff expects that the total plant water demand PPE value of
6,000 gpm would not result in water use conflicts in the Great Lakes, the Gulf of Mexico,
estuaries, intertidal zones, and oceans, because the plant demand would be negligible
compared to water availability. For smaller non-flowing water bodies (e.g., inland lakes, ponds,
and reservoirs), the impacts from competing water uses could manifest in different ways (e.g.,
reduction in downstream discharge from the water body, reduction in water surface elevation of
the water body, and reduction in nearshore habitat suitability) that depend on site-specific
hydrologic conditions. Therefore, these smaller water bodies fall outside the SPE value for
Surface Water Availability – Non-flowing in Appendix G.

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For both flowing and non-flowing sources, corresponding assumptions stated in Appendix G
should be met. If water is supplied by municipal systems, the staff assumes that the amounts
will be within the available capacity of the system. This is reflected in the PPE value for
municipal water availability.

3.4.1.1.2 Surface Water Quality

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In environmental reviews for large LWRs, the NRC staff typically evaluates the effects on
surface water quality from both construction and operation activities in terms of the degradation
of the ambient conditions of the water source and the resulting impacts on uses and users of
that source. During operations, surface water quality can be affected by the numerous
nonradioactive liquid effluents discharged from nuclear power plants. Discharges from the
cooling system usually account for the largest volumes of water and the greatest potential

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impacts on water quality and aquatic systems, although other systems may contribute heat and
contaminants to the effluent. Operation of these cooling systems may alter current patterns at
intake and discharge structures, salinity gradients, and thermal attributes of the receiving water
bodies. Water quality could be affected by temperature effects, sediment discharge, scouring,
eutrophication, and the discharge of water containing biocides, sanitary wastes, heavy metals,
and higher total dissolved solids (TDS) concentrations than those in the receiving water bodies.
During construction, surface water quality in nearby water bodies can be affected by runoff
containing sediments and other contaminants from industrial sites including any inadvertent
spills that ultimately reach these water bodies.

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Plant discharges must meet limits set forth in the CWA and specified in the applicable Federal,
State, and local permits received for the site. Discharge criteria are determined and
implemented by Federal and State agencies responsible for protection of resources based on
various project-specific conditions. As a result, criteria may vary among States and among
water body uses and types. To mitigate the effects of thermal discharges a mixing zone may be
established in the receiving water body such that changes from ambient temperatures outside of
the mixing zone are considered minor. The establishment of a mixing zone is highly
project-specific, as discussed in Section 3.4.2.2.7.

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The PPE/SPE specifies that if discharge water is sent to a municipal wastewater treatment
facility, the available capacity of the municipal system to treat effluents will exceed the expected
amount of plant effluent.

3.4.1.2

3.4.1.2.1 Groundwater Use

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Groundwater has typically been used for non-cooling-water supplies at proposed and operating
nuclear power plants. Groundwater has been used for common construction activities such as
dust abatement, soil compaction, and as a supply for concrete batch plants. Excavations of
plant foundations may also require dewatering or groundwater removal during
construction-related activities. Plants may continue dewatering during operations to maintain
low water levels near buildings and foundations. During construction and operation,
groundwater has also been used for systems that require a higher degree of water quality such
as potable and sanitary systems, service water, fire protection water, and plant systems that
require demineralized water. Applications for new large LWR nuclear power plants or early site
permits (ESPs) in the past have proposed to use groundwater for construction and/or operation.

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Nuclear plants that withdraw groundwater may affect the availability of groundwater for other
nearby users. Impacts could occur as a direct effect of withdrawing groundwater by lowering the
water table or indirectly by inducing the movement of lower quality water (e.g., saline water)
toward existing well users. Nearby groundwater users could also be affected indirectly if
construction or operation of the power plant were to disrupt the normal recharge of the
groundwater aquifer. The impacts of large groundwater withdrawal rates are likely to be more
significant for users located close to the plant boundary, and in areas where available water
resources are stressed. The magnitude of impacts from groundwater withdrawals is also
dependent on the site conditions and the hydrogeologic characteristics of the affected aquifer.
For example, groundwater pumping from confined aquifers tends to affect larger areas than
does pumping from unconfined aquifers for a given pumping rate, and for aquifers that are less
transmissive.

Groundwater Resources

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A permit from the State or other local/regional governing body is typically required to withdraw
groundwater. Permitting criteria may include the effects on water rights, availability of water,
interference with other beneficial uses, lowering groundwater levels (drawdown), and water
quality. The effects on connected surface water bodies (e.g., reductions in streamflow resulting
from groundwater withdrawals) may be a consideration. A permit exemption may be available in
areas when the withdrawal is less than a threshold value (e.g., 100,000 gpd or about equivalent
to a constant pumping rate of about 70 gpm), consistent with the expectation that lower
withdrawal rates would typically result in fewer impacts.

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For operating plants, the NRC staff has found that groundwater withdrawals of 100 gpm or less
created negligible or small impacts at operating nuclear power plants because this use rate
would not generally lower groundwater levels beyond the site boundary (NUREG-1437; NRC
2024-TN10161). Operating plant site areas are significantly larger than the site area SPE value
of 100 ac considered in this GEIS. Because some new nuclear reactor sites would be smaller
than large LWR sites, groundwater wells could be closer to the site boundary. As a result, the
NRC staff determined that the GEIS PPE/SPE should include a maximum groundwater
withdrawal rate less than 100 gpm, the rate used in the License Renewal GEIS (NRC 2024TN10161). In addition, the staff determined that the GEIS SPE should include limits on the
effects of withdrawals and dewatering on groundwater levels at the site boundary.

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The PPE and SPE parameter table in Appendix G specifies that groundwater withdrawals for all
plant uses (excluding dewatering withdrawals) be less than or equal to 50 gpm for a new
nuclear reactor. Based on simplified modeling, the NRC staff determined that effects on
groundwater levels at the site boundary from pumping 50 gpm on a 100 ac site would
approximate the effects from pumping 100 gpm on a larger site the size of a typical large LWR.
In addition, the staff assumed that the hydrogeologic properties of the aquifer are such that
groundwater withdrawals for plant uses would reasonably result in less than a 1 ft reduction in
groundwater levels at the site boundary. The threshold of 1 ft was selected as a de minimis
value likely to be less than the natural annual fluctuations in groundwater levels at most sites.
The groundwater withdrawal parameter also includes the assumption that plant groundwater
withdrawals would not occur in an aquifer designated by the EPA as a Sole Source Aquifer
(SSA), or in any aquifer designated by a State, tribe, or regional authority to have special
protections to limit drawdown. Groundwater withdrawals are also assumed to meet the
permitting requirements of applicable State and local agencies.

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The PPE/SPE specifies that groundwater withdrawals for dewatering also be no more than
50 gpm. The staff assumed the value of 50 gpm represents the long-term, steady dewatering
rate; the initial rate of dewatering may be larger. Based on simplified modeling, the NRC staff
determined that, relative to the plant site area, the effects on groundwater levels caused by
dewatering withdrawals of 50 gpm at a 100 ac site would be similar to the effects caused be
dewatering withdrawals of 100 gpm on a larger site the size of a typical large LWR. Consistent
with the site area used in this NR GEIS, the staff assumed in this simplified modeling that the
area to be dewatered and the depth of groundwater drawdown at the excavation/foundation
would be smaller for new nuclear reactors than for a typical large LWR. The PPE/SPE
dewatering parameter also includes assumptions that the hydrogeologic characteristics of the
site are such that dewatering has a negligible effect on groundwater levels at the site boundary
and that dewatering discharge does not affect the quality of the receiving water body.

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Because groundwater withdrawals could affect wetlands on or near the site, the SPE includes
assumptions that any changes in wetland water levels and hydroperiod caused by groundwater
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on wetlands. Potential groundwater use impacts on wetlands are discussed in
Sections 3.5.2.1.2 and 3.5.2.2.7 of this GEIS.

3.4.1.2.2 Groundwater Quality

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When conducting environmental reviews for large LWRs, the staff evaluates the potential effects
of plant construction and operation on current groundwater quality conditions. Groundwater
withdrawals could impair groundwater quality if they result in the movement of lower quality
groundwater. For example, long-term pumping of groundwater from coastal plain aquifers by
industrial and municipal facilities has contributed to saltwater intrusion in areas of nearly every
Atlantic and Gulf Coast State (Trapp and Horn 1997-TN1865; USGS 1990-TN6648).
Groundwater quality could also be impaired at inland sites where groundwater may be replaced
by poorer quality surface water through induced infiltration, or where groundwater has been
previously contaminated. Groundwater quality impacts are considered to be of small
significance when the plant does not contribute to changes in groundwater quality that would
preclude current and future uses of the groundwater. As with water use impacts, these types of
groundwater quality impacts are likely to be most significant when a plant withdrawal rate is
large.

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Groundwater quality may be affected by releases of potential contaminants to the subsurface.
Any intentional discharge of wastewaters to the subsurface would be regulated by the EPA as
required by 40 CFR Part 144 (Underground Injection Control Program) and/or State
underground injection control requirements. Spills or leaks from nuclear power plant facilities
can also impair groundwater quality. Nonradioactive materials such as fuels, solvents, and other
chemicals are typically stored and used at the nuclear power plants as part of general industrial
activities. Spills of these materials can occur during their use, and leaks from storage containers
and associated transfer lines can occur above and below the ground surface. Storage and
handling of fuels and chemicals are regulated by EPA and State requirements, and typically
require that spill prevention and response procedures be considered.

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NRC licensees are required to document and report the hazard of known releases of
radionuclides. However, inadvertent releases of radionuclides to groundwater may not be easily
detected and have resulted in groundwater contamination at operating nuclear power plants.
Operating plants have implemented a voluntary groundwater protection program to detect and
respond to inadvertent releases of radionuclides to groundwater (NEI 2019-TN6775). This
program includes characterization of site geology and hydrology, risk assessment for releases,
groundwater monitoring, establishment of a remediation protocol to prevent offsite migration
of radionuclides, and reporting of leaks/spills and groundwater monitoring results. Appendix I
to 10 CFR Part 50 provides the framework for the radiological environmental monitoring
program (REMP) by directing licensees to establish surveillance and monitoring
programs, including groundwater monitoring, for release of radionuclides. Guidance
related to the REMP is provided in RG 4.1 (NRC 2009-TN3802). In addition, 10 CFR 50.36a
(TN249) requires that licensees establish Technical Specifications to keep releases of
radioactive materials as low as reasonably achievable or ALARA.

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To minimize the potential groundwater quality impacts, the PPE and SPE parameter table in
Appendix G specifies that the plant will not be located in the recharge area for an
EPA-designated SSA, or in the recharge area for any aquifer designated by a State, tribe, or
regional authority to have special protections. Under the provisions of the Safe Drinking Water
Act (SDWA), States must establish demonstration programs for protection of critical aquifers. In
addition, the groundwater quality parameter in Appendix G specifies that the plant will not be

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located in a wellhead protection area or designated groundwater recharge area for a public
water supply well. It is also assumed that there are no planned plant discharges to the
subsurface, that applicable requirements and guidance on spill prevention and control are
followed, and that a groundwater protection program to detect and monitor inadvertent releases
is established and followed. If a new nuclear reactor is proposed for a site that does not conform
to these groundwater quality parameters and assumptions, a project-specific evaluation would
be required, and the NRC would consult with the jurisdictional authority and responsible
agencies when evaluating impacts.

3.4.2

Water Resources Impacts

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The NRC staff took four steps to develop a basis for determining values and assumptions for an
PPE and SPE for new nuclear reactors in order to determine which issues related to water
resources might be dispositioned generically (Category 1) and which would require a
project-specific evaluation (Category 2). First, the staff reviewed all EISs published since 2006
for new reactor projects that have received NRC permits and licenses to evaluate the
corresponding water use and summarize the resultant impact determinations. 6 Second, the staff
reviewed the License Renewal GEIS (NRC 2024-TN10161) to understand the key factors and
assumptions used to determine the impact level and category designation for water resource
issues. Third, the staff evaluated criteria for water withdrawal and discharge from three states
(Tennessee, Idaho, and Alaska), which are representative of variable regions and climates
where a new nuclear reactor might be sited, to develop a bounding set of PPE and SPE
parameters that are independent of a potential design or power rating. Lastly, the NRC staff
reviewed the applicable Federal and State regulations and permit requirements related to water
resources.

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Applicants for a new nuclear reactor license would be expected to obtain and comply with all
applicable permits and authorizations that regulate and limit impacts on the hydrologic
environment. Federal regulations administered by a State may be more restrictive than the
corresponding Federal regulations in order to account for unique regional or local environment
or environmental issues. As a result, the water-related authorizations may include, but not be
limited to, those listed in Appendix F of this GEIS. The applicant would also comply with other
applicable regional, State, tribal, and local regulations, which may include the following:

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• Water withdrawal registration and notification. Some States may require notification and
water withdrawal registration for amounts that exceed State-specified limits to aid in water
resource management during drought conditions.

• Water and sewer connection permits. Typically issued by a city, county, or municipal district.

3.4.2.1

Environmental Consequences of Construction

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Construction activities that may result in impacts on water quality, availability, and designated
use include the following:
6

Combined license EISs reviewed were those for Fermi Unit 3 (NRC 2013-TN6436), Levy Units 1 and 2
(NRC 2012-TN1976), North Anna Unit 3 (NRC 2010-TN6), South Texas Project Units 3 and 4
(NRC 2011-TN1722), V.C. Summer Units 2 and 3 (NRC 2011-TN1723), Vogtle Units 3 and 4 (NRC 2011TN6439), W.S. Lee Units 1 and 2 (NRC 2013-TN6435), and Turkey Points Units 6 and 7 (NRC 2016TN6434). ESP EISs reviewed were those for Clinton (NRC 2006-TN672), Grand Gulf (NRC 2006-TN674),
North Anna (NRC 2006-TN7), Vogtle (NRC 2008-TN673), PSEG (NRC 2015-TN6438) and Clinch River
NRC 2019-TN6136).

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• land clearing, grading, and placement of fill and spoils associated with site preparation

• construction of drainage and detention/retention features

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• construction of features at, in, or near-surface water bodies, which may include intake and
outfall structures, cofferdams, bulkheads, piers, jetties, and basins

• water channel modifications, including filling or dredging

• alteration of floodplains, natural drainage features or waterways near site

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• development of infrastructure such as roads, parking lots, laydown areas, and surface and
subsurface transmission lines (above and below ground)

• inadvertent spills of liquids (e.g., oil, fuel, diesel, solvents, wastewater)

• excavations and dewatering of building foundations

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• surface water, groundwater, or municipal water use for construction-related purposes (e.g.,
dust suppression, concrete batch plant, potable and sanitary water)

• discharges from stormwater runoff and sanitary systems.

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These construction activities may affect the quality and availability of surface water and
groundwater resources in the vicinity of the proposed site. The NRC staff identified and
evaluated the following environmental issues related to water use and quality, which may arise
from the construction activities listed above:

• surface water use conflicts during construction

• groundwater use conflicts due to excavation dewatering

• groundwater use conflicts due to construction-related groundwater withdrawals

• water quality degradation due to construction-related discharges

• water quality degradation due to inadvertent spills during construction

• water quality degradation due to groundwater withdrawal

• water quality degradation due to offshore or in-water construction activities

• water use conflicts due to plant municipal water demand

• degradation of water quality due to plant effluent discharges to municipal systems.

Each of the above environmental issues is discussed in more detail in the subsequent sections.

3.4.2.1.1 Surface Water Use Conflicts during Construction

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During construction, surface water may be used for activities such as dust abatement, concrete
mixing, and potable water needs. Construction-related water use is usually a small portion of the
amount of water needed for operation of a plant that has a water-cooled heat dissipation system
and because timeframes for construction are shorter. As a result, construction-related surface
water use impacts on water resources are typically less than operational impacts and, as such,
construction uses would be bounded by the total plant water demand limitation of 6,000 gpm (a
daily average) included in the PPE and SPE table (see Appendix G).

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No EIS for a plant licensed since 2006 has concluded that the impacts of surface water use
during construction would be greater than SMALL, even when surface water was the only
source of construction-related water. An example is the EIS for VC Summer Units 2 and 3, in
which the staff determined that construction-related surface water use would be about 1 percent
of the average makeup water withdrawn during operations (NRC 2011-TN1723); if a plant used
a mix of surface and groundwater resources for construction, then this percentage of surface
water use would be expected to be less.

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Acquiring water withdrawal permits and/or water rights for construction-related use has not
resulted in water use conflicts at large LWR sites. In addition, some new nuclear reactor
technologies are anticipated to require a smaller site footprint with a correspondingly reduced
reliance on water resources for construction than large LWR sites. Based on the preceding
discussion, the staff assumes that any applicable water withdrawal permits can be obtained,
and water rights can be acquired to support construction-related use at new nuclear reactor
sites. Therefore, the staff determined that the impacts on surface water use from construction of
a new nuclear reactor is a Category 1 issue. The staff concludes that, as long as the relevant
PPE and SPE criteria and assumptions are met for the applicable water body type, the impacts
on surface water use from building a new nuclear reactor can be generically determined to be
SMALL. This conclusion relies on the following PPE/SPE parameter and the associated value
and assumptions:

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• Total Plant Water Demand
–

Less than or equal to a daily average of 6,000 gpm.

If water is obtained from a flowing water body, then the following PPE/SPE parameter and
associated assumptions also apply:
• Surface Water Availability – Flowing

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–

Average plant water withdrawals do not reduce discharge from the flowing water body by
more than 3 percent of the 95 percent exceedance daily flow and do not prevent the
maintenance of applicable instream flow requirements.

–

The 95 percent exceedance flow accounts for existing and planned future withdrawals.

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–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
State, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

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If water is obtained from a non-flowing water body, then the following PPE/SPE parameter and
associated value and assumptions also apply:
• Surface Water Availability – Non-flowing

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–

Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and
intertidal zones exceeds the amount of water required by the plant.

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–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
state, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

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–

CZMA consistency determination is obtainable, if applicable, for the non-flowing water
body.

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3.4.2.1.2 Groundwater Use Conflicts Due to Excavation Dewatering

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Excavation dewatering during construction of building foundations may be required for any new
nuclear reactor project. Dewatering lowers groundwater levels adjacent to and beneath an
excavation to facilitate construction and increase the stability of excavation slopes (DOD 2004TN6814). Groundwater levels in the region surrounding the excavation will also be affected, and
the magnitude of the affected area will depend on the hydrogeologic conditions of the site, the
duration of dewatering, and the methods used to mitigate the effects of dewatering. Changes in
groundwater levels may locally affect the direction of groundwater flow, and may alter
groundwater recharge or discharge rates, including discharge to wetlands.

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The impacts of dewatering have been evaluated in the EIS for each of the licensed new reactor
sites. At these sites, dewatering rates were expected to be minimized by using engineering
practices to limit groundwater inflow to the excavations. In instances where dewatering impacts
were modeled, drawdown at the site boundary was typically less than the amount of seasonal
fluctuation in the surficial aquifer and water elevations were expected to rebound quickly when
dewatering ceased. With a single exception (i.e., the Grand Gulf ESP), impacts were expected
to be SMALL. In the Grand Gulf ESP EIS, the staff concluded that the impacts of water use,
including dewatering, on the underlying EPA SSA could not be determined because of
uncertainty in the plant design, planned pumping rates, and site characterization (NRC 2006TN674). Groundwater use conflicts, including the impacts of dewatering, were evaluated in the
License Renewal GEIS (NRC 2024-TN10161) and determined to be a Category 2 issue
(SMALL, MODERATE, or LARGE impacts depending on project-specific characteristics) for
plants that withdraw more than 100 gpm. Groundwater withdrawals of less than 100 gpm were
determined to have SMALL impacts because the effects on groundwater levels typically do not
extend beyond the site boundary (NRC 2024-TN10161).

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A dewatering rate of 50 gpm is specified in the PPE/SPE table (Appendix G) of this GEIS, as
discussed in Section 3.4.1.2.1. While this dewatering rate is less than the rate determined to
have SMALL impacts in the License Renewal GEIS, the staff determined that the 50 gpm value
is appropriate for the site size (100 ac) specified in the PPE/SPE table. The actual impacts of
dewatering at any particular site will depend on the size of the site, the area and depth of the
excavation, and the hydrogeologic characteristics of the site. In evaluating the impacts of
dewatering for this generic analysis, staff considered that excavations for some new nuclear
reactor sites are expected to be smaller, and the depth of groundwater drawdown at the
excavation are expected to be less, than those for the licensed fleet of large LWRs. With these
expectations, the staff used simplified modeling to determine that, relative to the plant site area,
the effects on groundwater levels caused by dewatering withdrawals of 50 gpm at a 100 ac site
would be similar to the effects caused by dewatering withdrawals of 100 gpm on a larger site the
size of a typical large LWR. Accepted methods for the design of dewatering systems (DOD
2004-TN6814) were used by staff in this impact evaluation. As specified in the PPE/SPE table,
dewatering is assumed to result in negligible drawdown at the site boundary. This indicates that
the radius of influence of the dewatering activities, (the distance beyond which pumping of a
dewatering system has no significant effect on ambient groundwater levels), does not extend
beyond the site boundary. With these specifications and assumptions, the staff determined that
the impacts of dewatering are likely to be localized at sites where the effective saturated
hydraulic conductivity of the surficial aquifer is no more transmissive than that represented by a
silty or very fine sand, or fractured/permeable rock. At smaller sites and sites that have more
transmissive aquifers, the staff assumed that additional engineering controls would be used to
avoid dewatering impacts beyond the site boundary.

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The staff has determined that groundwater use conflicts due to excavation dewatering during
construction of a new nuclear reactor is a Category 1 issue. The staff concludes that the effects
of dewatering activities related to the construction of new nuclear reactors would be localized
and temporary, and groundwater use conflicts from dewatering can be generically determined to
have a SMALL impact for this GEIS. This conclusion relies on the following PPE/SPE parameter
and the associated value and assumptions:
• Groundwater Withdrawal for Excavation or Foundation Dewatering

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–

The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate
may be larger).

–

Dewatering results in negligible groundwater level drawdown at the site boundary.

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Because wetlands located on or adjacent to the site may be affected by groundwater
withdrawals for excavation dewatering, the PPE/SPE includes the assumption that changes in
wetland water levels and hydroperiod resulting from groundwater use are within historical
annual or seasonal fluctuations, to avoid adverse impacts on nearby wetlands. Potential
groundwater use impacts on wetlands are discussed in Sections 3.5.2.1.2 and 3.5.2.2.7 of this
GEIS.

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Engineering controls may be required to achieve the limit on drawdown. As described in
Chapter 1, the staff anticipates that an application for a new nuclear reactor license will include
the appropriate data and analysis to establish with reasonable assurance that the proposed
project meets the conditions of the PPE/SPE with respect to dewatering, including the limitation
on drawdown at the site boundary. If the PPE/SPE conditions cannot be met, a project-specific
evaluation of the impacts of excavation dewatering is required.

3.4.2.1.3 Groundwater Use Conflicts Due to Construction-Related Groundwater Withdrawals

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During construction, groundwater may be used for activities such as dust abatement, concrete
mixing, and potable water needs. Groundwater withdrawals from one or more wells located on
the plant site will lower groundwater hydraulic head levels in the aquifer around the well(s). The
magnitude of the drawdown in hydraulic head and the extent of the affected area depend on the
withdrawal rate, the hydrogeologic conditions of the site, and the duration of withdrawal.
Changes in groundwater levels may locally affect the direction of groundwater flow, and may
alter groundwater recharge or discharge rates, including discharge to wetlands and streams.

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Construction-related groundwater withdrawal rates proposed for the licensed new reactor plant
and ESP sites planning to use only groundwater for construction (i.e., South Texas Project,
PSEG ESP, Vogtle, and Levy) ranged from 119 gpm to 420 gpm. In the final EIS (FEIS) for
each of these proposed plants, the staff determined these pumping rates would have a SMALL
impact on groundwater resources, in part due to the limited duration of construction and typical
associated withdrawal rates that are less than those proposed for plant operations.

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The withdrawal associated with construction use of groundwater would be subject to the
limitation of 50 gpm included in the PPE/SPE table (Appendix G), as discussed in
Section 3.4.1.2.1. This withdrawal limitation is more restrictive than the construction-related
groundwater withdrawal rates proposed for the four licensed sites referenced above. In addition,
the PPE/SPE assumes that withdrawals for plant use reduce groundwater heads at the site
boundary by no more than 1 ft, as discussed in Section 3.4.1.2.1. The 1 ft limit includes the
potential cumulative effect of simultaneous excavation or foundation dewatering and
groundwater withdrawal for plant use because dewatering is assumed to contribute negligible
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drawdown at the site boundary, as specified in Appendix G. The impacts of groundwater
withdrawals during operation are evaluated in Section 3.4.2.2.4 and found to be SMALL when
the specifications and assumptions of the PPE/SPE are met. Because the duration of
groundwater withdrawal would be shorter during construction than during operation, the staff
determined that the operational impacts bound those during construction for this issue. The staff
therefore concludes that this is a Category 1 issue. If actions required by appropriate permits
are implemented and applicable assumptions in the PPE and SPE are met (as described in
Section 3.4.2.2.4), water use conflicts related to groundwater withdrawals during construction of
a nuclear reactor will be minor, and impacts can be generically determined to be SMALL for this
GEIS.

3.4.2.1.4 Water Quality Degradation Due to Construction-Related Discharges

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During construction-related activities, runoff from disturbed and laydown areas can potentially
carry sediments to nearby surface water bodies. Because engineering controls (BMPs, silt
fences, detention basins, etc.) regulated by a combination of National Pollutant Discharge
Elimination System (NPDES) and USACE permitting are required during these activities,
construction-related impacts on surface water quality would be controlled, localized, and
temporary. Shallow groundwater withdrawn during dewatering of foundations during
construction could be discharged to surface water bodies on or near the site. The discharge rate
is limited to 50 gpm by the PPE/SPE value for groundwater excavation dewatering, as
discussed in Section 3.4.1.2.1. These discharges would be subject to the limits of an NPDES
permit designed to avoid adverse impacts on the receiving water body.

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The impacts on surface water quality from construction-related discharges were determined to
be SMALL in each of the EIS evaluations for new reactors because of adherence to the
conditions of the NPDES permit and because of the temporary nature of the discharge. The
staff expects that these impacts would be bounding for new nuclear reactors because
adherence to NPDES requirements would similarly be required and because of the PPE
assumption that the area disturbed would be relatively small (PPE values of 30 ac permanently
disturbed and 20 ac temporarily disturbed). Accordingly, the staff has determined that water
quality degradation due to construction-related discharges of a nuclear reactor is a Category 1
issue. The staff concludes that the effects of discharges related to the construction of new
nuclear reactors would be localized and temporary and impacts can be generically determined
to be SMALL. This conclusion relies on the following PPE/SPE parameters and the associated
values and assumptions:

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• Permanent Footprint of Disturbance – and Temporary Footprint of Disturbance
–

The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and
the temporary footprint of disturbance includes no more than an additional 20 ac or less
of vegetated lands.

• Impacts on Aquatic Biota
–

Adherence to requirements in NPDES permits issued by the EPA or State permitting
program, and any other applicable permits.

• Groundwater Withdrawal for Excavation or Foundation Dewatering

–

The long-term groundwater dewatering withdrawal rate is less than or equal to 50 gpm.

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–

Dewatering discharge has minimal effects on the quality of the receiving water body
(e.g., as demonstrated by conformance with NPDES permit requirements).

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The staff also concludes that water quality impacts on groundwater can be generically
determined to be SMALL. This conclusion relies on the following PPE/SPE parameter and the
associated value and assumptions:
• Groundwater Quality
–

There are no planned discharges to the subsurface (by infiltration or injection), including
stormwater discharge.

3.4.2.1.5 Water Quality Degradation Due to Inadvertent Spills during Construction

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During construction, inadvertent spills of gasoline, diesel fuel, hydraulic fluid, lubricants,
solvents, and wastewater used for construction equipment could affect both surface water and
groundwater resources. Pursuant to 40 CFR Part 112 (TN1041), applicants would be required
to use BMPs and implement a Spill Prevention, Control, and Countermeasure (SPCC) to
minimize the occurrence of spills and limit their effects. Impacts on water quality from
inadvertent spills during construction were determined to be SMALL in the EIS evaluations for
new reactors because of adherence to these spill prevention and pollution control measures.

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Building any nuclear reactor is expected to involve activities and methods similar to those for
building a large LWR. The associated BMPs and SPCC implementation are also expected to be
similar. Therefore, the staff has determined that water quality degradation due to inadvertent
spills during construction of a nuclear reactor is a Category 1 issue. The staff concludes that the
impacts of inadvertent spills on water quality during construction of a nuclear reactor can
generically be determined to be SMALL. This conclusion relies on the following PPE/SPE
parameters and the associated values and assumptions. This conclusion relies on the following
assumptions:

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• Site Size and Location
–

The site size is 100 ac or less

• Permanent Footprint of Disturbance and Temporary Footprint of Disturbance
–

The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and
the temporary footprint of disturbance includes no more than an additional 20 ac or less
of vegetated lands.

• Groundwater Quality
–

Applicable requirements and guidance on spill prevention and control are followed,
including relevant BMPs and SPCCs.

3.4.2.1.6 Water Quality Degradation Due to Groundwater Withdrawal

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Degradation of groundwater resources may occur when dewatering or withdrawal of
groundwater for plant uses induces the flow of lower quality water from the surrounding aquifers
or connected surface water bodies. This could result from pumping of deep confined aquifers
and dewatering of shallow, unconfined surficial aquifers.

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Groundwater withdrawals may induce infiltration from surface water (e.g., rivers, ponds, or
lakes), or contribute to saltwater intrusion from oceans and estuaries in aquifers near the coast.
In the License Renewal GEIS (NRC 2024-TN10161) the staff determined that pumping of
confined groundwater at operating plants in estuary or coastal sites had a small impact on

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groundwater quality. The pumping rates considered in the License Renewal GEIS greatly
exceed the PPE/SPE limits for groundwater withdrawals.

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In EISs for new reactors, the staff has generally determined that the impacts of dewatering of
the surficial aquifer would not extend far beyond the site boundary. At sites located near water
bodies of lower quality, such as PSEG, the surficial aquifer can be impacted. In that case, the
impacts were due to hydraulic connections with brackish Delaware River water limiting the
private use of groundwater in the area and the potential for further degradation (NRC 2015TN6438).

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The PPE/SPE table limits groundwater withdrawals for excavation dewatering and plant uses to
50 gpm each and assumes that groundwater withdrawals will result in no more than a 1 ft
lowering of groundwater levels at the site boundary, as discussed in Section 3.4.1.2.1. The 1 ft
limit includes the potential cumulative effect of simultaneous excavation dewatering and
groundwater withdrawal for plant uses because dewatering is assumed to contribute negligible
drawdown at the site boundary, as specified in the PPE/SPE table (Appendix G). In areas that
have exploitable groundwater resources, the PPE/SPE withdrawal rate is expected to be a small
fraction of the total withdrawal rate by other users (typically agricultural or municipal uses in
rural and urban areas, respectively). With no more than a 1 ft change in groundwater levels at
the site boundary, the potential for PPE/SPE withdrawals to induce flow from adjacent water
bodies is unlikely to be noticeable. In addition, the effects of groundwater withdrawals would be
limited to the period of construction.

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The staff has determined that water quality degradation due to groundwater withdrawals is a
Category 1 issue. The staff concludes that water quality impacts resulting from groundwater
withdrawals during construction of any new nuclear reactors would be localized and temporary
and can be generically determined to be SMALL for this GEIS. This conclusion relies on the
following PPE/SPE parameters and the associated values and assumptions:

• Groundwater Withdrawal for Excavation or Foundation Dewatering

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–

The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate
may be larger).

–

Dewatering results in negligible groundwater level drawdown at the site boundary.

• Groundwater Withdrawal for Plant Uses

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–

Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to
50 gpm.

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–

Withdrawal results in no more than 1 ft of groundwater level drawdown at the site
boundary.

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–

Withdrawals are not derived from an EPA-designated SSA, or from any aquifer
designated by a State, tribe, or regional authority to have special protections to limit
drawdown.

–

Withdrawals meet any applicable State or local permit requirements.

3.4.2.1.7 Water Quality Degradation Due to Offshore or In-Water Construction Activities

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Activities that may be associated with water quality degradation in lakes, rivers, and marine
environments include offshore or in-water construction of cofferdams; dredging operations;
placement of fill material into the water; creation of shoreside facilities involving bulkheads,

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piers, jetties, basins, or other structures or activities with potential to alter existing shoreline
processes; construction of intake and outfall structures; water channel modifications; and bridge
or culvert construction. Activities related to in-water building are localized and temporary, lasting
for the duration of the construction. These in-water building activities are regulated by provisions
of the CWA Section 404 (33 U.S.C. § 1344-TN1019) and Section 10 of the Rivers and Harbors
Appropriation Act of 1899 (33 U.S.C. §§ 401 et seq.; TN660). Adverse effects of these building
activities are traditionally controlled using BMPs like installation of turbidity curtains or
installation of cofferdams.
As such, the staff has determined that water quality degradation due to offshore or in-water
construction activities is a Category 1 issue and that the impacts could be generically
determined to be SMALL. This conclusion relies on the following PPE/SPE parameter and the
associated values and assumptions:
• In-Water Structures (including intake and discharge structures)

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–

Constructed in compliance with provisions of the CWA Section 404 (33 U.S.C. § 1344TN1019) and Section 10 of the Rivers and Harbors Appropriation Act of 1899 (33 U.S.C.
§§ 401 et seq.; TN660).

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Adverse effects of building activities controlled and localized using BMPs such as
installation of turbidity curtains or installation of cofferdams.

–

Construction duration would be less than 7 years.

3.4.2.1.8 Water Use Conflicts Due to Plant Municipal Water Demand

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Municipal water supply used to support construction-related water use (e.g., potable and
sanitary needs) may affect the municipal systems’ ability to meet their planned obligation to
other users. This plant need would only exist during the period of plant construction. To
generically assess the potential impact on municipal systems from the plant’s
construction-related water use, the staff assumed that the needed amount of municipal water
would be available and within the existing capacity of the municipal systems, thereby accounting
for all existing and planned future uses. If these assumptions are satisfied, the staff determined
that the plant’s construction-related municipal water use would not unduly stress the municipal
systems’ ability to meet their existing and planned obligations.

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The staff has determined that the effect of water supply from municipal systems is a Category 1
issue. The staff concludes that, as long as the relevant PPE and SPE are met the impacts on
municipal systems from building a nuclear reactor can be generically determined to be SMALL.
This conclusion relies on the following PPE/SPE parameter and the associated value and
assumptions:

• Municipal Water Availability

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–

The amount available from municipal water systems exceeds the amount of municipal
water required by the plant.

–

Municipal Water Availability accounts for all existing and planned future uses.

–

An agreement or permit for the usage amount can be obtained from the municipality.

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3.4.2.1.9 Degradation of Water Quality Due to Plant Effluent Discharges to Municipal Systems

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During construction, certain plant effluents (e.g., sanitary and sewer discharges) could be
discharged to a municipal wastewater treatment system. This plant effluent discharge would
only exist during the period of plant construction. To generically assess the potential impact on
the municipal wastewater system, the staff assumed that the municipal system has an existing
or planned capacity to treat all plant effluents while accounting for all existing and planned future
discharges. The staff further assumed that the plant effluent constituents can be treated by the
receiving system and therefore a permit can be obtained for construction-related plant effluent
discharge to the municipal systems.

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The staff has determined that the degradation of water quality from plant effluent discharges to
municipal systems is a Category 1 issue. The staff concludes that, as long as the relevant PPE
and SPE criteria are met the impacts on water quality from plant effluent discharges to
municipal systems related to building a nuclear reactor can be generically determined to be
SMALL. This conclusion relies on the following PPE/SPE parameter and the associated values
and assumptions:
• Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent

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–

Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent accounts for
all existing and reasonably foreseeable future discharges.

–

Agreement to discharge to a municipal treatment system is obtainable.

3.4.2.2

Environmental Consequences of Operation

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If the plant is water-cooled, the primary water-related impact would be associated with
withdrawals and discharges related to the cooling-water system. Potential impacts on water
quality, availability, and designated use may occur as a result of operations-related activities
that may include the following:

• maintenance dredging and disposal of dredged spoils

• groundwater dewatering of site structures to support plant operations

• surface water withdrawal at intake structures

• surface water discharge of plant blowdown and effluents to discharge structures

• groundwater withdrawal for plant use

• inadvertent spills of chemicals, fuels, solvents, and oils

• water supply from and discharges to municipal systems.

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As described in the following sections, the NRC staff identified the following environmental
issues related to water use, which may arise during operation:

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• surface water use conflicts during operations due to water withdrawal from flowing water
bodies

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• surface water use conflicts during operation due to water withdrawal from non-flowing water
bodies

• groundwater use conflicts due to building foundation dewatering

• groundwater use conflicts due to groundwater withdrawals for plant uses
3-42

• surface water quality degradation due to operation of intake and discharge structures

2
3

• surface water quality degradation due to changes in salinity gradients resulting from
withdrawals

• surface water quality degradation due to chemical and thermal discharges

• groundwater quality degradation due to plant discharges

• water quality degradation due to inadvertent spills and leaks during operation

• water quality degradation due to groundwater withdrawals

• water use conflict due to plant municipal water demand

• degradation of water quality due to plant effluent discharges to municipal systems.

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The potential impacts related to water use conflicts and water quality degradation are discussed
in the following sections.

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3.4.2.2.1 Surface Water Use Conflicts during Operation Due to Water Withdrawal from Flowing
Water Bodies

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The staff used a performance-based approach to identify a conservative and defensible SPE
criterion based on water availability at the new nuclear reactor site. The SPE criteria and
assumptions were developed for flowing (e.g., stream, canal, or river) and non-flowing (e.g.,
oceans, gulfs, intertidal zones, estuaries, lakes, ponds, and reservoirs) water bodies because
withdrawals affect each of these types of water bodies differently (see Appendix G). The SPE
criteria and assumptions for flowing water bodies are discussed in this section. SPE criteria and
assumptions for non-flowing water bodies are discussed in Section 3.4.2.2.2. Using these
performance-based criteria and assumptions potentially allows a larger number of sites in a
variety of hydrologic settings to fall within Category 1 under this GEIS.

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As discussed in Section 3.4.1.1, the staff determined that the total amount of surface water
withdrawn from surface water bodies for use by the nuclear reactor would be less than or equal
to 6,000 gpm, which is the PPE related to total plant water demand. This PPE value was
derived by considering the water needs of currently known ANR technologies. During
operations, some of this water would be consumed through evaporative loss or by other plant
systems. It is expected that operation-related water needs of some new nuclear reactors will be
much lower if the plant does not use water for cooling. The PPE limit includes water withdrawn
from surface water sources for use by all plant systems (cooling water, service water, fire
protection, potable, and sanitary) but does not include water from a municipal provider even if
the municipal provider obtained the water from a surface water source, because the impacts of
withdrawal by a municipal provider would have been considered in the provider’s withdrawal
permit. The staff estimated that the total plant water demand PPE is 5 to 10 times less than the
average surface water withdrawal rate proposed by the recently licensed large LWRs that
planned to rely predominately on flowing surface water bodies during operations (e.g., VC
Summer, WS Lee, and Clinch River). In each recently licensed large LWR, the impacts of water
withdrawal on surface water resources were determined to be SMALL, in part due to the
comparatively large amount of water available for use at each site. As a result of these factors,
the NRC staff determined that the PPE for total plant water demand conservatively supports a
generic impact determination when neither the design nor the site are currently known.

3-43

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The SPE criteria for surface water availability of a flowing water body was determined by
identifying the following:

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6

• An appropriate low flow characteristic to be used in the water impact assessment for flowing
surface water bodies. The staff chose to use the 95 percent exceedance flow of the flowing
surface water body as the flow characteristic for the impact assessment because this
characteristic is statistically representative of low flow conditions for that water body.

7
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9
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• A conservative impact measure of the low flow characteristic, which could be used to relate
withdrawal to the impact and category designation. Based on the evaluation described
below, the staff determined that plant withdrawals of 3 percent or less of the 95 percent
exceedance flow of the flowing surface water body would result in a SMALL impact and
Category 1 designation.

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14

• Constraints on the applicability of the Category 1 determination. These constraints were
developed by evaluating the previous EISs for circumstances that led to impacts that were
greater than SMALL and are included as assumptions for the SPE criteria.

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The staff developed the SPE criteria for water withdrawal (i.e., 3 percent of the 95 percent
exceedance flow) by evaluating the impacts related to plant use of flowing surface water bodies
in EISs for new reactors and the License Renewal GEIS for operating reactors (NRC 1996TN288 and NRC 2024-TN10161). In each recent EIS for new large LWRs withdrawing from
flowing surface water bodies, the staff determined that the impacts would be SMALL even
though maximum withdrawal rates were above 3 percent of the water available during low flow
conditions. The only exceptions to this were the proposed Grand Gulf and PSEG sites, where
the ratio of maximum plant withdrawal to availability during low flow conditions was much
smaller because of the size of the adjacent river resulting in SMALL impact determinations
(NRC 2006-TN674). The License Renewal GEIS discusses two plants where plant withdrawals
from flowing surface water bodies that exceeded 10 percent of minimum flows could result in
future water use conflicts (Limerick and Duane Arnold; NRC 1996-TN288). In both cases,
reducing the withdrawal to a much smaller percentage of the minimum flow, such as the SPE
value of 3 percent or less, would reduce the chances of future water use conflicts and minimize
impacts on other users. The SPE value of 3 percent would also comply with the EPA 316(b)
Proportional Flow Limitation (40 CFR 125.84(b)(3)(i) [TN254]), which specifies that plants not
withdraw more than 5 percent of the source water body annual mean flow.

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The staff’s generic analysis for water use impacts on flowing surface water bodies is described
here. The impact of water withdrawals on the resource is expected to be SMALL when the plant
withdrawal from a flowing surface water body is less than 3 percent of the 95 percent
exceedance flow and when assumptions stated in Appendix G are met. The criterion may be
described using the following equation:

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where 𝑄𝑤 is the plant water withdrawal rate and 𝑄95% i is the 95 percent exceedance flow (rate)
of the flowing surface water body.

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Using this relationship, a plant withdrawing water at the 6,000 gpm (the PPE limit) would need
to be sited on a flowing surface water body with a 95 percent exceedance flow of at least
200,000 gpm (approximately 450 cubic feet per second). Plants with lower withdrawal rates
could be sited on smaller flowing surface water bodies and be included in this generic analysis,
as illustrated by the shaded region in Figure 3-1. If this relationship is met, the staff has

𝑄𝑤 ≤ 0.03 × 𝑄95%

3-44

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3
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5
6

determined that surface water use conflicts during operations due to water withdrawal from
flowing surface water bodies is a Category 1 issue. This conclusion relies on the following
PPE/SPE parameters and the associated values and assumptions for the following parameters:
• Total Plant Water Demand
–

Less than or equal to a daily average 6,000 gpm.

• Surface Water Availability – Flowing

7
8
9

–

The 95 percent exceedance flow accounts for existing and planned future withdrawals.

11
12

–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
State, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

14
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16
17

Figure 3-1

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If the assumptions are not met or the plant water demand exceeds the PPE, assessing surface
water use impacts would require a project-specific evaluation in the SEIS.

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28

Radial (Ranney©) collector wells have been proposed for some new reactor sites and may be
proposed to supply water for future nuclear reactors. Radial collector wells are installed within
an aquifer and have a direct, productive connection to a surface water body so that they can
withdraw water from the surface water body that is of better quality, due to bank filtration, while
minimizing impacts such as sedimentation and scouring in the surface water body. Because
these wells either directly pump surface water or are removing groundwater that is discharging
to a surface water body, the PPE/SPE values and assumptions for surface water availability and
the evaluation of surface water use conflicts above also apply to withdrawals from radial
collector wells.

SMALL Surface Water Use Impacts for Plant Withdrawals of 6,000 gpm or
Less Compared to the 95 Percent Exceedance Discharge in the Flowing
Surface Water Body

3-45

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2

3.4.2.2.2 Surface Water Use Conflicts during Operation Due to Water Withdrawal from
Non-flowing Water Bodies

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7

The staff considers the water availability of some non-flowing surface water bodies, i.e., the
Great Lakes, the Gulf of Mexico, estuaries, intertidal zones, bays, and oceans, to be large water
bodies compared to the total plant water demand PPE value of 6,000 gpm. For example, in the
EIS for Fermi (NRC 2013-TN6436), the staff determined that the annual water withdrawal
amounted to an inconsequential amount (0.0014 percent) of the volume of Lake Erie.

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The staff considers that smaller non-flowing surface water bodies (e.g., inland lakes,
manufactured ponds, and reservoirs) have limited water availability. These water bodies are not
included in the staff’s generic analysis. The water availability in these smaller non-flowing
surface water bodies may be allocated or planned for multiple uses. Therefore, withdrawing
water for use from these smaller non-flowing surface water bodies is more likely to result in
surface water use conflicts. The impacts from the competing water use could manifest in
different ways (e.g., reduction in downstream discharge from the water body, reduction in water
surface elevation of the water body, and reduction in nearshore habitat suitability) that depend
on site-specific hydrologic conditions. The staff has determined that impacts of plant water
withdrawal from these smaller non-flowing surface water bodies on surface water resources will
be assessed in a project-specific analysis in the SEIS.

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24

As a result, the staff determined that the impact of surface water use from these large nonflowing surface water bodies is a Category 1 issue. The staff concludes that if the conditions
and assumptions of the PPE and SPE are met the impact on surface water resources from plant
water withdrawal from these large non-flowing surface water bodies would be negligible and can
be generically determined to be SMALL. This conclusion relies on the following PPE/SPE
parameters and the associated values and assumptions for the following parameters:

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27

• Total Plant Water Demand
–

Less than or equal to a daily average of 6,000 gpm.

• Surface Water Availability – Non-flowing

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–

Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and
intertidal zones exceeds the amount of water required by the plant.

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31

–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
State, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

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34

–

Coastal Zone Management Act of 1972 (16 U.S.C. §§ 1451 et seq.; TN1243)
consistency determination is obtainable, if applicable.

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37

The discussion related to radial collector wells that withdraw water from flowing surface water
bodies in Section 3.4.2.2.1 is also relevant if water were withdrawn using radial collector wells
from a non-flowing surface water body.

3.4.2.2.3 Groundwater Use Conflicts Due to Building Foundation Dewatering

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The potential impacts of excavation dewatering are described in Section 3.4.2.1.2, in which the
staff concluded that dewatering during construction is expected to result in a SMALL impact on
groundwater resources. This conclusion relied on the PPE/SPE specification that the
dewatering rate is less than 50 gpm and the assumption that dewatering results in negligible
3-46

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3
4

alterations in groundwater levels at the site boundary. The basis for the PPE/SPE values and
assumptions are discussed in Section 3.4.1.2.1. The effects of dewatering building foundations
during plant operation would be similar to those occurring during construction, but the
magnitude of the effects may increase because of the longer period of operation.

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The combined impact of operational dewatering and plant groundwater use for large LWRs was
evaluated in the License Renewal GEIS (NRC 2024-TN10161). Based on a review of operating
plants, the staff concluded in the License Renewal GEIS that plants withdrawing less than
100 gpm (for operational dewatering or for plant uses) would have SMALL impacts. However,
the staff also determined that plants withdrawing more than 100 gpm have the potential to
create conflicts with other local groundwater users if groundwater levels are lowered beyond the
site boundary. For these plants, the staff concluded that the impacts of groundwater withdrawals
cannot be determined generically.

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When evaluating the impacts of dewatering in Section 3.4.2.1.2, the staff noted that although
the PPE/SPE dewatering rate of 50 gpm is less than the rate determined to have SMALL
impacts in the License Renewal GEIS, the actual impacts of dewatering at any particular site will
depend on the size of the site, the area dewatered, the depth of groundwater drawdown at the
dewatering location (i.e., the building foundations), and the hydrogeologic conditions of the site.
As a result, the actual effects of dewatering on groundwater levels are uncertain and this
uncertainty increases with the duration of the projected need for dewatering. The staff relied on
the temporary nature of dewatering during construction in concluding that the impacts of
dewatering during construction would be SMALL. Because dewatering of building foundations
could occur for the duration of operations, the potential impacts of operational dewatering could
be larger than those of the relatively shorter period of construction.

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The effects of dewatering on groundwater levels would be monitored, and appropriated
mitigation would be used with the PPE/SPE conditions met, the effects of dewatering will be
localized to the plant site and therefore unlikely to result in groundwater use conflicts. On this
basis, the staff has determined that groundwater use conflicts due to building foundation
dewatering during operation of a nuclear reactor are a Category 1 issue. The staff concludes
that the effects of dewatering activities related to the operation of nuclear reactors would be
localized to the plant site, and groundwater use conflicts from dewatering can be generically
determined to have a SMALL impact for this GEIS. This conclusion relies on the following
PPE/SPE parameter and the associated values and assumptions.

• Groundwater Withdrawal for Excavation or Foundation Dewatering

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–

The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate
may be larger).

–

Dewatering results in negligible groundwater level drawdown at the site boundary.

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Because wetlands located on or adjacent to the site may be affected by building foundation
dewatering during operations, the PPE/SPE includes the assumption that changes in wetland
water levels and hydroperiod resulting from groundwater use are within historical annual or
seasonal fluctuations, to avoid adverse impacts on nearby wetlands. Potential groundwater use
impacts on wetlands are discussed in Sections 3.5.2.1.2 and 3.5.2.2.7 of this GEIS.

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As discussed in Chapter 1, the staff anticipates that an application for a new nuclear reactor
license will include the appropriate data and analysis to establish with reasonable assurance
that the proposed project meets the conditions of the PPE/SPE with respect to dewatering,
including the limitations on groundwater withdrawal rate and on drawdown at the site boundary.
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If the PPE/SPE conditions cannot be met, a project-specific evaluation of the impacts of
excavation dewatering is required.

3.4.2.2.4 Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses

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Construction use of groundwater is discussed in Section 3.4.2.1.3. Groundwater may be used
during operations for various plant purposes, including potable, sanitary, process, and cooling
uses. The operational effects of groundwater use would be similar to those described for
construction, with the principal difference being that the duration of pumping for operations
would be significantly longer. When evaluating impacts, the staff considered an operational
period of 40 years. Groundwater withdrawals from one or more wells located on the plant site
will lower groundwater hydraulic head levels in the aquifer around the well(s), and the
magnitude of the drawdown in hydraulic head and the extent of the affected area tend to
increase with the duration of the withdrawal. As noted previously, changes in groundwater levels
may locally affect the direction of groundwater flow, and may alter groundwater recharge or
discharge rates, including discharge to wetlands and streams.

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The staff reviewed recent new reactor EISs and found that the proposed groundwater pumping
rates exceeding 100 gpm were determined to have a SMALL impact on groundwater resources.
In each case, this conclusion was made, in part, because the site locations and specific
pumping rates were known and could be fully evaluated. In one instance (Grand Gulf), where
the plant design and groundwater withdrawal rate were uncertain, and where withdrawals would
be from an EPA-designated SSA, the staff concluded that a MODERATE impact was possible
(NRC 2006-TN674).

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Based on a review of groundwater withdrawals for operational purposes at existing plants, the
staff reported in the License Renewal GEIS (NRC 2024-TN10161) that impacts on water
resources could vary based on geographic location, especially if pumping rates exceeded
100 gpm. As a result, the staff determined that groundwater use conflicts are a Category 2 issue
(SMALL, MODERATE, or LARGE impacts depending on project-specific characteristics) for
plants that withdraw more than 100 gpm. For plants that withdraw less than 100 gpm, the staff
determined that groundwater use conflicts were a Category 1 issue and concluded that these
plants would have SMALL impacts because the effects on groundwater levels do not usually
extend beyond the site boundary (NRC 2024-TN10161).

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A groundwater withdrawal rate of 50 gpm is specified in the PPE/SPE table (Appendix G), as
discussed in Section 3.4.1.2.1. While this withdrawal rate is less than the rate determined to
have SMALL impacts in the License Renewal GEIS, the actual impacts of groundwater
withdrawals at any particular site will depend on the size of the site. The site size (100 ac)
specified in the PPE/SPE table is much smaller than the areas of operating plants and licensed
new reactors (e.g., the Clinch River site proposed for a small modular reactor is more than
900 ac). In evaluating the impacts of groundwater use for this generic analysis, the staff
considered the 100-ac size specified in the PPE for reactor sites and used a distance between
the pumped well and the site boundary of about 1,000 ft (the distance of a well located at the
center of a square 100 ac site). As noted below, mitigation to prevent significant impacts may be
required if the well is closer to the site boundary. The staff’s analysis used a single well,
screened over the entire depth of an infinite (in area), homogeneous aquifer, and withdrawing
50 gpm for 40 years. As specified in the PPE/SPE table, and discussed in Section 3.4.1.2.1,
groundwater withdrawals are assumed to result in no more than 1 ft of drawdown at the site
boundary.

3-48

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Given the specifications and assumptions described above, groundwater drawdown at any
distance from the pumped well can be estimated with an analytical approach for radial flow to a
well (e.g., Freeze and Cherry 1979-TN3275). Because drawdown depends on the
hydrogeological properties of the aquifer (which is unknown for a generic site), the staff
evaluated the effects of groundwater use for a representative range of aquifer properties. The
staff determined that the impacts of groundwater withdrawals are likely to be localized (i.e.,
groundwater drawdown beyond the site boundary is less than 1 ft) at sites where the effective
transmissivity is greater than about 5,000 ft2/d for withdrawals from an unconfined aquifer and
greater than 10,000 ft2/d for withdrawals from a confined aquifer. These transmissivity values
imply aquifers that are productive sources of groundwater, with well-specific capacities in the
range of 25 to 40 gpm/ft of drawdown (Driscoll 1986-TN6823). At smaller sites or sites where
the pumped well is located closer to the site boundary, and at sites with less transmissive
aquifers, additional mitigation may be needed to avoid groundwater use conflicts (e.g., reducing
the withdrawal rate or altering the location of the well with respect to other groundwater users).

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20

The staff determined that groundwater use conflicts due to groundwater withdrawals during
operation of a nuclear reactor is a Category 1 issue. The staff concludes that the effects of
groundwater use related to the operation of nuclear reactors would be localized to the site area
and groundwater use conflicts from withdrawals for plants uses can be generically determined
to have a SMALL impact for this GEIS. This conclusion relies on the following PPE/SPE
parameter and the associated value and assumptions:

• Groundwater Withdrawal for Plant Uses

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23

–

Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to
50 gpm.

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25

–

Withdrawal results in no more than 1 ft of groundwater level drawdown at the site
boundary.

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28

–

Withdrawals are not derived from an EPA-designated SSA, or from any aquifer
designated by a State, tribe, or regional authority to have special protections to limit
drawdown.

–

Withdrawals meet any applicable State or local permit requirements.

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32
33
34

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37
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39

As described in Chapter 1, the staff anticipates that an application for a new nuclear reactor
license will include the appropriate data and analysis to establish with reasonable assurance
that the proposed project meets the conditions of the PPE/SPE with respect to groundwater
withdrawals for plant use. If the PPE/SPE conditions cannot be met, a project-specific
evaluation of the impacts of groundwater withdrawal is required.

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41

3.4.2.2.5 Surface Water Quality Degradation Due to Physical Effects from Operation of Intake
and Discharge Structures

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Cooling-water intake and discharge structures have the potential to create localized impacts on
surface water quality through physical effects such as alterations of current patterns, scouring,
sediment transport, and increased turbidity. The License Renewal GEIS reports that (NRC
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2024-TN10161) these impacts have typically been small for operating reactors, in part due to
adherence to Section 316 of the CWA (33 U.S.C. § 1326; TN4823) and because effects are
limited to the area of the intake and discharge structure. Section 316(b) of the CWA requires
that the “best technology available for minimizing adverse environmental impact” be used for
cooling-water intake structure. This has made the use of once-through cooling-water systems
unlikely for new power plants. Any applicant for a new nuclear reactor license that uses intake
or discharge structures as part of the cooling or water supply system would also need to comply
with the same requirements of Section 316(b) of the CWA and the conditions of the NPDES
permit that would be required for the site.

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Because the effects of intake and discharge structures are dependent on water withdrawal and
discharge rates, the staff expects that the plant discharge rate would be less than the
withdrawal rate. The withdrawal rate is based on the PPE limit for total plant water demand and
any applicable SPE values and assumptions for the selected water source (Surface Water
Availability for Flowing or Non-flowing water bodies). For flowing water bodies, withdrawals
would be limited to the total plant water demand PPE/SPE value of 6,000 gpm and be 3 percent
or less of the 95 percent low flow value for the water body as explained in Section 3.4.2.2.1. For
non-flowing water bodies, withdrawals would also be limited to the total plant water demand
PPE/SPE value of 6,000 gpm and be subject to SPE values and assumptions.

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25

The staff has determined that degradation of surface water quality due to operation of intake
and discharge structures is a Category 1 issue. The staff concludes that the impacts on the
aquatic environment from the alteration of current patterns, scouring, sediment transport, and
increased turbidity would be localized to the vicinity of these structures, and therefore the impact
on surface water quality can be generically determined to be SMALL. This conclusion relies on
the following PPE/SPE parameters and the associated values and assumptions for the following
parameters:

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28

• Total Plant Water Demand
–

Less than or equal to a daily average of 6,000 gpm.

• Intake and Discharge Structures

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30

–

Adhere to best available technology requirements of CWA 316(b) (33 U.S.C. § 1326TN4823).

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33

–

Operated in compliance with CWA Section 316 (b) and 40 CFR 125.83, including
compliance with monitoring and recordkeeping requirements in 40 CFR 125.87 and
40 CFR 125.88, respectively (40 CFR Part 125-TN254).

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36

–

Best available technologies are employed in the design and operation of intake and
discharge structures to minimize alterations due to scouring, sediment transport,
increased turbidity and erosion.

–

Adherence to requirements in NPDES permits issued by the EPA or a given state.

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39

• If water is obtained from a flowing water body, then the following PPE/SPE parameter and
associated value also applies.

• Surface Water Availability – Flowing

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–

The average rate of plant withdrawal does not exceed 3 percent of the 95 percent
exceedance daily flow for the water body.

3-50

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7

If water is obtained from a non-flowing water body, then the following PPE/SPE parameters and
associated values and assumptions also apply:
• Surface Water Availability – Non-flowing
–

Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and
intertidal zones exceeds the amount of water required by the plant.

3.4.2.2.6 Surface Water Quality Degradation Due to Changes in Salinity Gradients Resulting
from Withdrawals

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Power plant withdrawals may cause alterations to salinity concentrations and salinity gradients if
the source water body is an estuary or intertidal zone. As a result, States with estuaries or
intertidal zones typically require consideration of the effect of power plant withdrawals on the
alteration of salinity regimes as part of the development of permits.

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The impacts of water withdrawal and discharge on salinity gradients near operating nuclear
power plants, including those located on estuaries or intertidal zones, were evaluated by the
staff for the 2013 License Renewal GEIS (NRC 2024-TN10161). The 2013 License Renewal
GEIS drew upon project-specific examples provided in the 1996 License Renewal GEIS
(NRC 1996-TN288) to conclude that altered salinity gradients were expected to be noticeable
only in the immediate vicinity of the intake and discharge structures. The 1996 License Renewal
GEIS considered the impacts to be SMALL and designated this a Category 1 issue. To develop
this GEIS, the staff considered the conclusions and examples provided in both the 1996 License
Renewal GEIS and the 2013 revision. In one example shared in the 1996 GEIS, the staff noted
that a fossil-fuel plant located on the same large estuary as a nuclear plant, was found to have
altered natural salinity patterns because it was sited in a shallower area. This illustrates that,
even in large estuaries, the degree of impact is somewhat dependent on the location of the
plant. Siting may be an even more important factor when a smaller water body is involved. In
addition, the 1996 GEIS noted that impacts were also dependent on whether alterations to
salinity gradient were, “…within the normal tidal or seasonal movements of salinity gradients
that characterize estuaries” (NRC 1996-TN288).

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For this GEIS, the staff recognizes that for water bodies other than estuaries and intertidal
zones, maintaining the natural salinity regime is not a critical issue and is not typically included
in water quality criteria for that water body. As noted above, in sensitive water bodies such as
estuaries or intertidal zones, factors that affect the magnitude of potential impacts include the
size of the water body, the placement of the plant intake structures in relation to the water body,
and any changes in the normal range and movement of the salinity gradients that characterize
that water body. These factors are project-specific and are considered important in the
development of the impact level for nuclear reactors that may be sited in a variety of locations
and water body types.

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For this GEIS, the staff has determined that degradation of surface water quality due to changes
in salinity gradients resulting from withdrawal is a Category 1 issue that can be generically
determined to be SMALL. This conclusion relies on the following PPE/SPE parameter and the
associated values:

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42

• Total Plant Water Demand
–

Less than or equal to a daily average 6,000 gpm.

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3

If water is obtained from a flowing water body, then the following PPE/SPE parameter and
associated assumptions also apply:
• Surface Water Availability – Flowing

4
5
6

–

The 95 percent exceedance flow accounts for existing and planned future withdrawals.

8
9

–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
State, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

11
12

–

If withdrawals are from an estuary or intertidal zone, then changes to salinity gradients
are within the normal tidal or seasonal movements that characterize the water body.

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15

If water is obtained from a non-flowing water body, then the following PPE/SPE parameter and
associated values and assumptions also apply:
• Surface Water Availability – Non-flowing

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–

Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and
intertidal zones exceeds the amount of water required by the plant.

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–

Water availability is demonstrated by the ability to obtain a withdrawal permit issued by
State, regional, or tribal governing authorities.

–

Water rights for the withdrawal amount are obtainable, if needed.

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–

If withdrawals are from an estuary or intertidal zone, then changes to salinity gradients
are within the normal tidal or seasonal movements that characterize the water body.

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The Coastal Zone Management Act of 1972 (16 U.S.C. §§ 1451 et seq.; TN1243) consistency
determination is obtainable, if applicable. The finding applies to all water bodies. However,
based on the discussion above, for estuaries and intertidal zones, the staff’s impact conclusion
relies on the SPE assumption, adopted from the License Renewal GEIS, that changes to salinity
gradients be localized near the intake of the power plant and remain within the normal tidal or
seasonal movements of salinity gradients that characterize the water body. If PPE and SPE
values and assumptions are not met, then a project-specific evaluation will be required.

3.4.2.2.7 Surface Water Quality Degradation Due to Chemical and Thermal Discharges

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During operations, nuclear plants may discharge water from the cooling, service, and sanitary
water system to surface water bodies near the plant. If the plant is water-cooled, the largest
volume of discharge and the greatest potential impacts on water quality are associated with the
heat and chemical constituents in the effluent discharged from the cooling-water system.
Discharges typically contain increased TDS, salinity, biocides, heavy metals, and other
contaminants that may have been included in the withdrawn cooling water but become
concentrated due to evaporative loss during the cooling process. Some chemicals may also be
added to the withdrawn water before it is discharged (e.g., biocides). Impacts on surface water
from plant discharge may vary based on the quality and rate of the plant discharge and the
characteristics of the receiving water body, some of which are related to location. These
location-dependent characteristics may include natural variations in temperature, salinity levels,
or normal tidal or seasonal movements of salinity gradients.
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To operate, power plants must obtain an NPDES permit under Section 402 of the CWA
(33 U.S.C. § 1342-TN4765). The permit specifies discharge standards and monitoring
requirements, and licensees are required to be in compliance with the limits set by the permit.
NPDES permits are issued by the EPA or, more commonly, a designated State water quality
regulatory agency.

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The staff performed a review of the historical impacts of discharges from known plant discharge
designs on well-understood sites and determined that the impacts were determined to be of
small significance (NRC 2024-TN10161). The staff also reviewed EISs for licensed new reactors
and determined that the impacts of discharges during operations on surface water quality would
be SMALL, with one exception. This exception occurred in the Grand Gulf ESP EIS, where the
staff concluded that the impacts of plant discharges on the Mississippi River water quality were
not able to be determined because “…the bounds of concentrations of chemical effluents” for all
waste streams had not been provided in the PPE or ER (NRC 2006-TN674). For both operating
and proposed sites, the conclusion that impacts on water quality would be SMALL was reached
after a project-specific review. These project-specific reviews included an estimation of the
extents of the mixing zones in the receiving water bodies and how the mixing zone may affect
aquatic resources under site-specific conditions (e.g., geometry, ambient discharge
characteristics, ambient water quality characteristics, aquatic habitat, and designated uses of
the water body).

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During the evaluation conducted for this GEIS, the staff sought to develop a comprehensive
bounding set of water quality criteria, including both thermal and chemical criteria, for use in the
PPE and SPE. The staff found this to be impractical and determined that it would not ultimately
be beneficial to the GEIS. Development of a bounding list for the PPE was complicated by
uncertainties in how a new, advanced plant design might affect cooling systems, and the
thermal and chemical characteristics of the discharges.

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Development of a bounding set of characteristics for the SPE was challenging for the reasons
presented below.

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First, a State with delegated permitting authority may impose limitations on temperature and
effluent that are tailored to the conditions of the State and they may be more stringent than
those required by the EPA. These State-specific conditions include characteristics of the
receiving water body such as type (e.g., ocean, lake, river), designated use (e.g., water supply,
agricultural use, recreational), ambient temperature, ambient water quality and assimilative
capacity, and the significance of the aquatic habitat (e.g., spawning zones). For example,
contaminant concentration standards for domestic water supplies prescribed by the States of
Tennessee (TN 0400-40-03-TN7038) and Alaska (18 AAC 70-TN7039) are more restrictive than
the legally enforceable standards required by the National Primary Drinking Water Regulations
of the SDWA.

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Second, the more stringent criteria developed by States may vary. The staff reviewed the
acceptable temperature ranges in discharges and the resulting thermal impacts on receiving
water bodies for Tennessee, Alaska, and Idaho and found them to vary (TN 0400-40-03TN7038; 18 AAC 70-TN7039; IDAPA 58.01.02-TN7040). This variance between States results
primarily from the difference in the ambient temperature of the water bodies caused by the
regional climate as well as the tolerance for temperature variations of the aquatic species
present in the water bodies. In addition, States with estuaries or intertidal zones (e.g., Maryland)
typically require consideration of the effect of power plant discharges on the alteration of salinity
regimes at the discharge site as part of the NPDES permits. State with these zones may set

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more restrictive limits on salinity and require greater evaluation of potential impacts of the
discharge on salinity gradients than states without these zones.

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9

Third, if permits establish effluent limits that exceed water quality criteria a regulatory mixing
zone may be determined, for which individual requirements can be established on a case-bycase basis. In theory, impacts could be negligible if the potential for significant dilution of effluent
discharge and minimization of thermal and salinity impacts in the receiving water body exists.
However, computation of an acceptable dilution factor for permits often factors in limits on
mixing zone sizes set by States for specific water bodies, making the dilution factor projectspecific.

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15

Lastly, development of a bounding set of plant parameters for the PPE or site parameters for
the SPE was not considered beneficial for this GEIS, because compliance with water quality
standards set forth in the NPDES permit does not necessarily equate to a SMALL impact (i.e.,
indicating no noticeable impact on surface water quality of the resource; see 10 CFR 51.71(d),
footnote 3 [TN250]). Therefore, a project-specific evaluation would be necessary to develop the
impact determination as part of a SEIS.

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22

As a result, the staff determined that degradation of surface water quality from chemical and
thermal discharges requires consideration of project-specific information on a case-by-case
basis. Therefore, the staff determined that the degradation of surface water quality due to
chemical and thermal discharges is a Category 2 issue (SMALL, MODERATE, or LARGE
impacts depending on project-specific characteristics). The staff concludes that the impact on
surface water quality due to chemical and thermal discharges should be determined on a caseby-case basis using project-specific information in a SEIS.

3.4.2.2.8 Groundwater Quality Degradation Due to Plant Discharges

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Based on reviews of proposed large LWRs and existing plants, the staff has determined that the
discharge to surface water bodies during operation would not noticeably impact groundwater
resources. However, some existing and proposed plants discharge, or plan to discharge, plant
effluents directly to groundwater via deep well injection or indirectly to groundwater via
infiltration from ponds or canals. Water discharged to a cooling pond has elevated
concentrations of TDS and other constituents and could infiltrate into the underlying
groundwater system. The significance of the groundwater quality impacts would depend on
cooling pond water quality, site hydrogeologic conditions, and the location, depth, and pumping
rate of offsite wells. The potential for impacts is decreased in areas that have poorer
groundwater quality, such as coastal areas and salt marshes (NRC 2024-TN10161), but all
plant discharges to the subsurface have the potential to degrade groundwater quality. At the
Turkey Point site, in-depth, project-specific analysis of the potential effects of discharge from an
operating plant located above an EPA-designated SSA has also been conducted. The staff
evaluated the impacts of infiltration of hypersaline water from the operation of Units 3 and 4
discharged into the cooling-canal system (NRC 2019-TN6824). The staff found that infiltration of
plant effluents into the shallow aquifer underlying the canal has had a significant impact on
groundwater quality on and off the plant site. In the Turkey Point Units 6 and 7 EIS (NRC 2016TN6434), the staff also evaluated the potential impact of injection of plant discharge into a deep
aquifer. The staff ultimately determined that deep well injection would lead to a SMALL impact.
However, this determination relied upon a detailed project-specific evaluation.

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Because the potential impacts on groundwater can be significant, the PPE/SPE groundwater
quality parameter specifies that a new nuclear plant be located outside the recharge area for

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any aquifer designated to have special protections. In addition, the PPE/SPE specifies that the
plant be outside the designated contributing area for any public water supply well. Because any
discharge of plant effluents to the subsurface would have significant potential impacts on
groundwater quality, the PPE/SPE also assumes that there would be no planned discharges to
the subsurface via either direct injection or via infiltration from ponds or canals. Based on these
PPE/SPE values and assumptions, the staff has determined that groundwater quality
degradation due to plant discharges during operation of a nuclear reactor is a Category 1 issue.
The staff concludes that the discharges can be generically determined to have a SMALL impact
on groundwater quality. This conclusion relies on the following PPE/SPE parameter and the
associated values and assumptions:
• Groundwater Quality

12
13

–

The plant is outside the recharge area for any EPA-designated SSA or any aquifer
designated to have special protections by a State, tribal, or regional authority.

14
15

–

The plant is outside the wellhead protection area or designated contributing area for any
public water supply well.

–

There are no planned discharges to the subsurface (by infiltration or injection).

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18

If these PPE/SPE values and assumptions are not met, a project-specific evaluation of the
impacts of groundwater withdrawal is required.

3.4.2.2.9 Water Quality Degradation Due to Inadvertent Spills and Leaks during Operation

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26

During operation, inadvertent spills of gasoline, diesel fuel, hydraulic fluid, lubricants, solvents
and wastewater used for construction equipment could impact both surface water and
groundwater resources. Pursuant to 40 CFR Part 112 (TN1041), applicants would be required
to use BMPs and implement a SPCC to minimize the occurrence of spills and limit their effects.
While not necessarily uncommon at operating nuclear power plants, minor chemical spills have
not constituted widespread, consistent water quality impacts because they are readily amenable
to correction (NRC 1996-TN288).

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During operation, features of the stormwater discharge system, such as retention basins, may
increase infiltration over the area of the basin and increase local recharge to groundwater,
thereby potentially affecting groundwater quality. Stormwater discharge would be regulated
under the NPDES permit and it would conform to the terms of the NPDES permit, including
monitoring of discharge water quality for potential inadvertent releases. In recent EISs for
proposed large LWRs the NRC staff has assumed that the system would be designed to
preclude discharge to groundwater during operations and, as a result, plant runoff during
operations would not affect groundwater quality.

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Radionuclide leaks from plant components and pipes have occurred at numerous plants (NRC
2023-TN10129). Groundwater protection programs have been established at all operating
nuclear power plants to minimize potential impacts from inadvertent releases (NEI 2019TN6775). The License Renewal GEIS evaluated the impacts from leaks occurring at operating
reactor sites and determined that that if leaks were to occur, the magnitude of impacts would be
dependent on project-specific characteristics (NRC 2024-TN10161). The staff concluded in the
License Renewal GEIS that, because the impacts of radionuclide leaks to groundwater could be
greater than SMALL and must be based on a project-specific analysis, this is a Category 2
issue.

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While contamination from inadvertent leaks have occurred at operating plants, the staff
determined that this operating experience is not sufficient to preclude a generic determination
on this issue for the operation of new nuclear reactors. As a result, the staff has determined that
water quality degradation due to inadvertent spills during operation of a nuclear reactor is a
Category 1 issue. The staff concludes that the impacts of inadvertent spills on water quality
during operation of a nuclear reactor site would be SMALL. This conclusion relies on the
following PPE/SPE parameters and the associated values and assumptions:
• Groundwater Quality

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10

–

Applicable requirements and guidance on spill prevention and control are followed,
including relevant BMPs and SPCCs.

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12

–

There are no planned discharges to the subsurface (by infiltration or injection), including
stormwater discharge.

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–

A groundwater protection program conforming to NEI 07-07 (NEI 2019-TN6775) is
established and followed.

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•

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Site Size and Location
– The site size is 100 ac or less.
Permanent Footprint of Disturbance
–

Use of BMPs for soil erosion, sediment control, and stormwater management.

• Impacts on Aquatic Biota
–

Adherence to requirements in NPDES permits issued by the EPA or a given State, and
any other applicable permits.

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If the PPE/SPE conditions are not met, a project-specific evaluation of the impacts of
inadvertent spills and leaks is required.

3.4.2.2.10 Water Quality Degradation Due to Groundwater Withdrawals

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Water quality degradation due to groundwater withdrawals during construction is discussed in
Section 3.4.2.1.6. Degradation of groundwater resources may occur when dewatering or
withdrawal of groundwater for plant uses induces the flow of lower quality water from the
surrounding aquifers or connected surface water bodies. Groundwater withdrawals may induce
infiltration from surface water (e.g., rivers) or contribute to increased saltwater intrusion from
nearby oceans and estuaries in aquifers already impacted by saltwater intrusion. The effects of
groundwater withdrawals during operation of a nuclear reactor would be similar to those during
construction, but they would occur over a longer duration.

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In the License Renewal GEIS (NRC 1996-TN288 and NRC 2024-TN10161) the staff reported
that operating plants in estuary or coastal sites that pumped groundwater from confined aquifers
at rates between 400 gpm and 1,000 gpm had a small effect on groundwater quality, especially
when the plant’s withdrawal rate was a small fraction of the regional total groundwater use. In
the EISs for new large LWRs, groundwater pumping during operation was determined to have a
SMALL impact on groundwater resources at all sites except for Grand Gulf. In the Grand Gulf
ESP EIS (NRC 2006-TN674) the staff evaluated a range of potential pumping rates because the
estimates of the pumping rate were not provided. The staff determined that high groundwater
withdrawal rates (from radial collector wells) could induce flow of lower quality groundwater from
deeper aquifers upward into the Catahoula (an EPA-designated SSA) and significantly degrade
water quality.

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The PPE/SPE table limits groundwater withdrawals for building foundation dewatering and plant
uses to 50 gpm and assumes that groundwater withdrawals will result in no more than a 1 ft
lowering of groundwater levels at the site boundary. The basis for the PPE/SPE values and
assumptions is discussed in Section 3.4.1.2.1. The 1 ft limit includes the potential cumulative
effect of simultaneous dewatering and groundwater withdrawal for plant uses because
dewatering is assumed to contribute negligible drawdown at the site boundary, as specified in
the PPE/SPE table (Appendix G). In areas that have exploitable groundwater resources, the
PPE/SPE withdrawal rate is expected to be a small fraction of the total withdrawal rate by other
users (typically agricultural or municipal uses in rural and urban areas, respectively). With
minimal changes in groundwater levels at the site boundary, the potential for PPE/SPE
withdrawals to induce flow from adjacent water bodies is unlikely to be noticeable.

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The staff has determined that water quality degradation due to groundwater withdrawals is a
Category 1 issue. The staff concludes that water quality impacts resulting from groundwater
withdrawals during operation of the any nuclear reactors would be localized and can be
generically determined to be SMALL for this GEIS. This conclusion relies on the following
PPE/SPE parameters and the associated values and assumptions:

• Groundwater Withdrawal for Excavation or Foundation Dewatering

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19

–

The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate
may be larger).

–

Dewatering results in negligible groundwater level drawdown at the site boundary.

• Groundwater Withdrawal for Plant Uses

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23

–

Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to
50 gpm.

24
25

–

Withdrawal results in no more than 1 ft of groundwater level drawdown at the site
boundary.

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–

Withdrawals are not derived from an EPA-designated SSA, or from any aquifer
designated by a State, tribe, or regional authority to have special protections to limit
drawdown.

–

Withdrawals meet any applicable State or local permit requirements.

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32
33

If any of the PPE/SPE conditions are not met, a project-specific evaluation of the water quality
impacts of groundwater withdrawals is required. For example, use of a radial collector well
during operation is likely to involve withdrawals that exceed the 50 gpm PPE/SPE value, which
will require a project-specific evaluation of potential water quality degradation.

3.4.2.2.11 Water Use Conflict Due to Plant Municipal Water Demand

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Municipal water supply used to support water use (e.g., potable and sanitary needs) during
plant operations may affect the municipal systems’ ability to meet their planned obligation to
other users. To generically assess the potential impact on municipal systems from the plant’s
operation-related water use, the staff assumed that the needed amount of municipal water is
available and within the existing or planned capacity of the municipal systems while accounting
for all existing and planned future uses. If these assumptions are satisfied, the staff determined
that the plant’s operation-related municipal water use will not unduly stress the municipal
systems’ ability to meet their existing and planned obligations.

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The staff has determined that the effect of water supply from municipal systems is a Category 1
issue. The staff concludes that, as long as the relevant PPE and SPE are met, the impacts on
municipal systems from operating a nuclear reactor can be generically determined to be
SMALL. This conclusion relies on the following PPE/SPE parameter and the associated values
and assumptions:
• Municipal Water Availability

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8

–

Usage amount is within the existing capacity of the system(s), accounting for all existing
and planned future uses.

–

An agreement or permit for the usage amount can be obtained from the municipality.

3.4.2.2.12 Degradation of Water Quality Due to Plant Effluent Discharges to Municipal Systems

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During operation of a plant, certain plant effluents (e.g., sanitary and sewer discharges) could
be discharged to a municipal wastewater treatment system. To generically assess the potential
impact on the municipal wastewater system, the staff assumed that the municipal system has
an existing or planned capacity to treat all plant effluent while accounting for all existing and
planned future discharges. The staff further assumed that the plant effluent constituents can be
treated by the receiving system and therefore a permit can be obtained for operation-related
plant effluent discharge to the municipal systems.

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24

The staff has determined that the degradation of water quality from plant effluent discharges to
municipal systems is a Category 1 issue. The staff concludes that, as long as the relevant PPE
and SPE are met (e.g., the plant effluent discharge is bounded by municipal wastewater
systems’ capacity) and appropriate permits can be obtained, the impacts on water quality from
plant effluent discharges to municipal systems from operating a nuclear reactor can be
generically determined to be SMALL. This conclusion relies on the following PPE/SPE
parameter and the associated values and assumptions:

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26
27

• Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent
– Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent accounts for
all existing and reasonably foreseeable future discharges.
–

Agreement to discharge to a municipal treatment system is obtainable.

3.5

Terrestrial Ecology

3.5.1

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Any site proposed for a new reactor would contain terrestrial habitat of some type. Even land
areas with past industrial or urban development provide habitat for terrestrial species. The NRC
staff expects that most proposed new reactor sites would contain some naturally vegetated land
such as forest, scrub, grassland, or wetlands; landscaped land such as lawns or mowed areas;
or agricultural land such as cropland, pasture, and orchard. Sites may also contain active or
abandoned structures, pavement, rubble, borrow pits, or strip-mined lands. In natural habitats,
the vegetation present may be the climax vegetation featuring species composition typical for
the landscape position after long periods without human or natural disturbance, or it may be
successional vegetation influenced by more recent disturbance. Sites may be greenfield,
without a history of nonagricultural development, or all or part of a proposed site may contain
operating or abandoned power generation facilities or other industrial facilities. More information
about how the NRC staff defines and characterizes terrestrial habitats is available in RG 4.11
(NRC 2012-TN1967).

Baseline Conditions and PPE/SPE Values and Assumptions

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Vegetation varies greatly across the United States. Vegetation is typically forest in humid
settings receiving high rainfall but may be grassland (prairie), shrubland, or desert vegetation in
drier or rockier settings or areas subject to past disturbance, or taiga (boreal forest) or tundra in
permafrost settings. Wetlands are intermediate between terrestrial and aquatic habitat types.
Wetlands are delineated using the Corps of Engineers Wetlands Delineation Manual (USACE
1987-TN2066) and regional supplemental guidance recognized by the USACE and may or may
not be under the jurisdiction of the CWA protecting wetlands and threatened and endangered
species, and relevant scientific literature. Some assumptions made in this section of this GEIS
involve parameters and values adapted from previous staff environmental reviews or are the
subject of Federal regulations; some have been appropriately scaled down to account for the
size and technology differences between large LWRs and smaller reactors. In every case, the
staff has selected a value or parameter that will ensure a SMALL impact on terrestrial resources
from building and operation of a reactor after considering all available information and
leveraging professional judgment and expertise.

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Based on information contained in past new reactor EISs and the staff’s ability to scale that
information to smaller reactors, the staff includes an assumption in the PPE and SPE that calls
for the permanent disturbance of no more than 30 ac of vegetated (unpaved) terrestrial habitat,
and temporary disturbance of an additional 20 ac of vegetated terrestrial habitat. However, the
PPE and SPE assume that any temporarily disturbed habitat would be restored using regionally
indigenous vegetation once the new facilities are built. The staff reasons that disturbance to
larger areas could potentially result in substantial effects on regional ecosystems. The
assumptions also recognize limitations on the type and quality of terrestrial habitat disturbed.
There can be no ecologically sensitive features within the disturbed areas (footprint of
disturbance), such as floodplains, shorelines, riparian vegetation, late-successional vegetation,
land specifically designated for conservation, or habitat known to be potentially suitable for one
or more Federal or State threatened or endangered species. In addition, the PPE assumes that
there can be no more than 0.5 ac of wetlands or other surface waters impacted by the entire
project. This value is based on the fact that many Nation Wide Permits (NWPs) established
under the CWA (33 CFR Part 330-TN4318) allow up to 0.5 ac of project-wide disturbance to
wetlands and other waters of the United States. Additionally, drawing from analyses in past new
reactor EISs, the staff included an assumption in the PPE and SPE of a maximum building
height of 50 ft, except for 200 ft for meteorological towers and 100 ft for transmission line
poles/towers and mechanical draft cooling towers. The PPE assumes new meteorological
towers will have non-red, flashing lights. The Federal Aviation Administration recommends
voluntary marking of meteorological towers <200 ft AGL and does not permit red non-flashing
lights on any new tower above 150 ft AGL to reduce the number of migratory bird collisions
(FAA 2020-TN10130; FCC 2017-TN10131). The PPE and SPE likewise assume no noise
generation greater than 85 decibel(s) on the A-weighted scale (dBA) at a point 50 ft from the
source. The assumptions in the PPE and SPE regarding site employment (Section 3.12.2) also
apply to the staff’s evaluation of potential impacts on wildlife from vehicular traffic.

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As presented in Section 3.1, the staff assumes that offsite ROWs for transmission lines,
pipelines, and access roads are not more than 1 mi in length or 100 ft in width, but may be
unlimited in mileage for linear features built within existing ROWs or in widened ROWs directly
adjacent to existing ROWs or public highways. The staff recognizes that these values would
effectively minimize disturbance to terrestrial habitats and wildlife in most surrounding
landscapes. Additionally, the NRC staff assumes that the total disturbance to any wetlands (as
delineated using the Corps of Engineers Wetlands Delineation Manual [USACE 1987-TN2066]
and regional supplements) and other surface waters from the entire project (including onsite and
offsite activities) would not exceed 0.5 ac (based on criteria underlying many NWPs).

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Otherwise, the staff does not assume other qualitative limitations on other habitats that may be
present in proposed offsite ROWs, because only a small fraction of the area would be disturbed
by support foundations and most of the ROW area would be spanned by overhead power lines.
In addition, the staff assumes there would be no physical disturbance to streams greater than
10 ft in width below the ordinary high-water mark. While the potential impacts on most such
narrow streams would be localized, physical disturbance to larger streams could potentially
affect more distant connected wetland and shoreline habitats.

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The staff assumes that licensees would comply with State and local regulatory requirements for
implementing BMPs for soil erosion, sediment control, and stormwater management whenever
ground-disturbing activities take place either onsite or offsite. Even if a project is proposed for
somewhere lacking such regulatory requirements, the staff assumes for purposes of its generic
analyses that licensees would voluntarily implement BMPs similar to those commonly required
by most States and local jurisdictions. The staff also assumes that any impacts on wetlands or
other waters of the United States can be permitted through general permits rather than
individual permits, and that licensees would implement any mitigation called for in the permits.

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The NRC staff typically evaluates effects on terrestrial resources in terms of habitats and broad
groupings of wildlife, as well as on the individual species and habitats that meet the definition of
“important” species and habitats outlined in RG 4.2 (NRC 2024-TN7081). Determining which
species and habitats potentially affected by a project meet the criteria for “important” is not
possible until a specific site and ROWs are identified. While the analysis in Section 3.5.2 is able
to consider the potential effects on many types of important species generically, it reserves
consideration of potential effects on federally listed threatened or endangered species until after
receipt of an application. Several available mapping tools and databases contain relevant
information about potential important species for sites anywhere in the United States. The U.S.
Fish and Wildlife Service (FWS) maintains online mapping tools and databases regarding the
potential occurrence of threatened, endangered, proposed, or candidate species and critical
habitats designated under the Federal ESA (16 U.S.C. §§ 1531 et seq.; TN1010). As of 2024,
the FWS mapping tool is termed Information for Planning and Consulting (IPaC). Users can
enter an action area (potentially affected area) polygon into IPaC which then generates a list of
potentially occurring listed species and habitats as well as other ecologically useful information.
Users can also use IPaC to automatically generate an official species letter that serves the
same function as the official species letters that agencies formerly used to request from the
FWS in writing. The FWS also continues to add automated features that help in assessing
potential impacts to certain listed species. Most States have Natural Heritage Programs with
databases containing known locations of species and habitats with Federal or State special
designations.

3.5.2

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For most new reactors, terrestrial ecology impacts related to loss, conversion, and
fragmentation of upland and wetland habitats and habitats for threatened or endangered
species would primarily take place during preconstruction, especially during site preparation
work such as clearing, grubbing, and grading. Potential impacts related to exposure of wildlife to
noise or the potential for collision of birds and bats with structures and transmission lines could
continue throughout the building period and extend into operations. Issues related to the
exposure of flora and fauna to cooling-tower drift, radiological releases, EMFs, or the risk of
avian electrocution on powerlines are more of a concern during operations.

Terrestrial Ecology Impacts

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3.5.2.1

Environmental Consequences of Construction

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The NRC staff identified the following environmental issues for analysis for the building of a new
reactor:

• permanent and temporary loss, conversion, fragmentation, and degradation of habitats;

• permanent and temporary loss, conversion, and degradation of wetlands;

• effects of building noise on wildlife;

• effects of vehicular collisions on wildlife; and

• bird collisions with structures.

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In addition to evaluating the issues noted above, the NRC staff addressed as a separate issue
any impacts on important species and habitats as defined for NRC environmental reviews in
RG 4.2 (NRC 2024-TN7081).

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3.5.2.1.1 Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of
Habitats

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Because of the assumptions in the PPE and SPE outlined in Section 3.5.1, building a new
reactor would not require permanent disturbance of more than 30 ac of land or temporary
disturbance of more than 20 ac of additional land, within a site no larger than 100 ac. The
assumptions also limit impacts on wetlands (addressed further in Section 3.5.2.1.2) and exclude
impacts on floodplains, riparian land, late-successional vegetation, land specifically designated
for conservation, or habitat potentially suitable for one or more Federal or State threatened or
endangered species. These assumptions are conservative regarding parameters related to
terrestrial ecology and recognize the high degree of variability in the sensitivity of various
habitats and species in various landscape settings. Habitat that is permanently lost to build a
reactor would no longer provide food or cover for terrestrial flora or fauna. However, loss of
50 ac of habitat not situated in sensitive settings is unlikely to noticeably reduce the overall
availability of such habitat for most species in the surrounding landscape. Many of the EISs for
new LWRs over the last 10 years have identified noticeable impacts on terrestrial habitats (e.g.,
those for Levy and Turkey Point; NRC 2012-TN1976 and NRC 2016-TN6434, respectively), but
these proposed reactors have each encompassed hundreds of acres of habitat loss,
substantially exceeding the PPE used in this GEIS. Much of the terrestrial habitat outside of
sensitive settings consists of current or former agricultural land, pasture or degraded range land,
forest monocultures, or ruderal habitat compromising the presence of invasive plant species
such as cheatgrass (Bromus tectorum), red brome (Bromus rubens), garlic mustard
(Alliaria petiolata), stiltgrass (Microstegium vimineum), or ailanthus (Ailanthus altissima). Losses
of such degraded habitat on new reactor sites are unlikely to noticeably limit resources for most
species in the surrounding landscape. Even for higher-quality habitats such as late-successional
forest, scrub, or prairie vegetation, the loss of only 50 ac is unlikely to result in a noticeable
decline in the ecological quality of the surrounding landscape.

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However, the staff recognizes the typically long time horizon following past disturbance that is
necessary for late-successional vegetation to develop, particularly in arid regions where
vegetation recovery and succession are poorly understood (Abella 2010-TN6722; Engel and
Abella 2011-TN6721; McAuliffe 1988-TN6723). Thus, project-specific review of the plans would
be necessary to evaluate the value of late-successional habitats and the consequences of
losing the ecological services they provide. In many settings, the individualized review may

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reveal that impacts from losses of those habitats might be minimal, but the staff considers
individualized review to be necessary. The assumptions in the PPE and SPE therefore exclude
late-successional vegetation from the onsite footprint of disturbance. Applicants would likely
select sites located in areas of relatively low habitat value.

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Habitat conversion involves changing habitat to a different habitat type. Habitat conversion
typically involves a change from a more mature to a less mature vegetational stage (Abella
2010-TN6722) that may be then maintained indefinitely (e.g., from forest to shrub or grassland
within a ROW). Habitat conversion may also include the cutting of forest near new reactors to
open sightlines for security purposes. Unlike habitat loss, converted habitat continues to provide
food or cover for terrestrial flora or fauna, but food or cover that is different from and perhaps
inferior to that provided by the original habitat. When habitat changes, basic elements of an
ecosystem upon which a species relies for shelter, food, and reproduction may be altered or
may no longer be available. Habitat generalists may be able to adapt more readily to such
changes than habitat specialists. Habitat conversion may result in a shift in species dominance
and composition (Abella 2010-TN6722). Disturbance to convert habitats may also provide an
opportunity for increased establishment of invasive species. Habitat conversion over small
parcels is unlikely to noticeably limit resources for most species in the surrounding landscape.

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Fragmentation of mature forests or rangeland habitats, and other high-quality terrestrial habitats
can be as harmful to wildlife as habitat losses, because it can limit wildlife movement and
migration and limit access to food, water, and other resources, as well as increase the amount
of edge habitat and invasive species resulting in habitat degradation and increased predation.
Fragmentation can result from new clearings or the establishment of new features such as
roads or fences that can interfere with the movement of wildlife. Fragmentation of natural
habitats by human activity is recognized as being a key contributor to biodiversity losses over
five continents (Haddad et al. 2015-TN6563). In North America, forest fragmentation has been
shown to have adverse effects on neotropical migratory birds (birds that nest in the tropics and
migrate north to breed in summer) through small forest-patch size, reduced proximity of
patches, more edge, and negative interactions with non-forest species, in addition to those from
habitat loss (Boulinier et al. 2001-TN6724, Critical Area Commission 2000-TN6564). Lynch
(1987-TN6726) described the negative insular effects of forest fragmentation on neotropical
migrants in terms of reduced patch size and isolation in the eastern United States. Yahner
(2000-TN6565) demonstrated that the probability of four neotropical migratory bird species
favoring forest interiors in the eastern United States declined sharply in forest tracts of less than
100 ha (247 ac). Initially, forest fragmentation triggers effects on a local scale, resulting in a
range retraction of populations to less fragmented parts of a region (Rolstad 2008-TN6725).
Similar effects have been shown to result from fragmentation of rangeland vegetation in the
Midwest and Western North America. Schoerlbel (2003-TN6727) and Knick and Rotenberry
(1995-TN6728, 2002-TN6729) demonstrated the effects of shrub-steppe fragmentation on
songbirds requiring sagebrush (Artemisia spp.) habitat. Smith (2016-TN6730) demonstrated that
the fragmentation of 1 mi2 of shrub-steppe habitat for agricultural development can reduce
sage-grouse (Centrocercus urophasianus) population persistence within an area 12 times that
size. The FWS highlighted similar implications of fragmentation by energy development to
sage-grouse, other sagebrush-dependent species, and the greater sagebrush ecosystem (FWS
2014-TN6731).

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The assumptions in the PPE and SPE would effectively ensure minimization of losses and
fragmentation of late-successional vegetation. Technical guidance on minimization of loss and
fragmentation of habitats is available for most habitat types. Most call for locating new
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new infrastructure to avoid affecting late-successional habitats where possible (Critical Area
Commission 2000-TN6564; Paige and Ritter 1999-TN6802).

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Clearing new offsite ROWs, even those under 100 ft in width, can fragment large blocks of
forest and rangeland, reduce the availability of habitat to forest-interior and area-sensitive
wildlife to an extent greater than suggested by the acreage of clearing. Rich et al. (1994TN6732) demonstrated that narrow forest-dividing corridors as small as 8 m (26 ft) can
substantially reduce the abundance of forest-interior neotropical migrant birds. Creating new
offsite ROWs with upright structures such as poles and towers increases perching habitat for
predators and can increase predation for populations of at-risk species in sagebrush
ecosystems (e.g., sage-grouse) (Manier et al. 2014-TN6746). However, the PPE limits the
length of new offsite ROWs not co-located with or adjacent to existing utilities or roads to less
than 1 mi, ensuring that the potential fragmentation of habitat and associated indirect risks to
wildlife (e.g., predation) would be minimal. The NRC staff anticipates (but does not assume, for
purposes of this analysis) that applicants would strive to locate new offsite ROWs whenever
possible in areas of low extant habitat value and sufficiently distant from any seasonal
habitats (e.g., nesting areas) to minimize predation risk.

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The staff has determined that permanent or temporary loss, conversion, fragmentation, or
degradation of nonsensitive habitats is a Category 1 issue. The staff concludes that, as long as
the applicable assumptions in the PPE and SPE are met, impacts from building a new reactor
can be generically determined to be SMALL. The staff relied on the following PPE and SPE
values and assumptions to reach this conclusion:

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• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation
once the lands are no longer needed to support building activities.

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

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• The footprint of disturbance (permanent and temporary) would contain no ecologically
sensitive features such as floodplains, shorelines, riparian vegetation, late-successional
vegetation, land specifically designated for conservation, or habitat known to be potentially
suitable for one or more Federal or State threatened or endangered species.

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• Total wetland impacts from use of the site and any offsite ROWs would be no more than
0.5 ac (see Section 3.5.2.1.2 below).

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• Applicants would demonstrate an effort to minimize fragmentation of terrestrial habitats by
using existing ROWs, or widening existing ROWs, to the extent practicable.

• BMPs would be used for erosion, sediment control, and stormwater management.

3.5.2.1.2 Permanent and Temporary Loss and Degradation of Wetlands

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The assumptions would ensure that there would be no more than 0.5 ac of wetlands within the
footprint of disturbance, and hence subject to filling, on the site and in the offsite ROWs (except
for building intake and discharge structures if needed). A project meeting the assumptions
would most likely not require an Individual Permit under Section 404 of the CWA; 33 U.S.C. §
1344-TN1019).

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Wetlands for purposes of the analyses contained in this NR GEIS include the lands that meet
the criteria for delineation as wetlands as established in the USACE Wetlands Delineation
Manual (USACE 1987-TN2066) and applicable regional supplementary wetland delineation
guidance, regardless of whether they meet other criteria required for jurisdiction under the CWA
(33 CFR Part 328-TN1683). Many wetlands not meeting the criteria for jurisdiction under the
CWA, sometimes termed “isolated wetlands” or “non-jurisdictional wetlands,” can still provide
beneficial ecological services such as contributing to groundwater recharge, attenuating
overland surface runoff thereby reducing flooding potential, and providing specialized habitat for
many wetland-dependent wildlife species. Many depressional features such as vernal pools,
prairie potholes, Carolina bays, and playa lakes play key roles in flood control and groundwater
recharge, and provide specialized habitat required by many wildlife species that are declining
rapidly in many regions, yet are isolated from navigable waterways and surface tributary
systems and hence not under the jurisdiction of the CWA. Because the functions and values of
wetlands are not dependent on whether the wetland is under CWA jurisdiction, the staff
established the 0.5 ac assumed limit on wetland disturbance to be inclusive of impacts on any
wetlands regardless of jurisdictional status under the CWA.

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The 0.5 ac of wetlands might be physically lost or disturbed by site preparation work, commonly
referred to as “discharge of dredged or fill material,” or by other types of disturbances. The
hydrology of wetlands, and hence biota that rely on the hydrological properties of wetlands, can
also be altered by changes in landscape drainage patterns and overland runoff. Wetlands are
also subject to sedimentation from upgradient soil disturbances. Wetland losses and
disturbances cause the loss or reduction of multiple hydrological functions such as groundwater
recharge and discharge, flood flow abatement, and shoreline stabilization; ecological functions
such as fish and wildlife habitat, production export, and providing specialized habitat for many
threatened or endangered species; and societal values such as recreation and aesthetics
(USACE 1999-TN1793).

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Excavations to build a reactor can cause temporary drawdowns of the water table, thereby
influencing the hydrology and hence the water levels, hydroperiod (number and timing of days
per year that soils remain saturated or covered with water), spatial extent and function of nearby
wetlands. Even for large reactors, however, analyses in recent EISs have indicated that some
hydrological effects on wetlands might be brief and localized. A conservative analysis of the
drawdown effects of excavating 56 ft deep to build a large pond component for the proposed
Bell Bend nuclear power plant in Pennsylvania, and pumping groundwater at a rate of 235 to
310 gpm, estimated that the effects of water table drawdown on nearby wetlands would last only
as much as 24 months and not extend more than about 1,200 ft from the excavation (NRC and
USACE 2016-TN6562). Analysis of water table drawdowns during excavations for the proposed
Levy Units 1 and 2 in a landscape in north-central Florida containing extensive wetlands
concluded that the drawdown effects on adjoining wetlands would be temporary and within the
range of expected seasonal water table fluctuations to which the wetlands are adapted
(NRC 2012-TN1976). Both analyses assumed, however, that nearby wetlands would be
monitored over the period of excavation and action would be taken to restore water levels as
necessary. Based on these analyses, for a new reactor bounded by the assumptions for
groundwater withdrawals and dewatering in the SPE (50 gpm with negligible effect on
groundwater levels at the site boundary), onsite wetlands with a groundwater connection could
be affected, but similar wetlands offsite would not be affected. Temporary adverse impacts on
onsite wetlands can result if groundwater dewatering causes changes in water levels or
hydroperiod that exceed historical annual or seasonal fluctuations. This applies to all onsite
wetlands with a groundwater connection, and the effects may be accentuated in wetlands that
only have a surface water connection. The staff expects that applicants relying on the generic

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analysis would demonstrate that the assumption regarding the influence of groundwater
withdrawal for dewatering on connected wetlands (changes in wetland water levels and
hydroperiod are within historical annual or seasonal fluctuations) in the SPE are met. If this
assumption is not met, then project-specific analysis would be necessary to demonstrate that
impacts are minimal.

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Wetlands may also be affected by habitat conversion. One of the most notable types of habitat
changes in wetland water levels and hydroperiod within historical annual or seasonal fluctuation
conversions that may occur in association with new reactors is forest clearing for the purpose of
spanning wetlands with transmission lines (EPA 2018-TN6747). The removal of vertical habitat
structure reduces the diversity of species and creates corridors that fragment forests (addressed
in previous section) (EPA 1994-TN6748). Canopy and subcanopy trees are typically removed,
eliminating nesting habitat for forest-interior bird species. Extant shade-tolerant forest
understory vegetation may change to herbaceous and/or shrub species adapted to full-sun
conditions. Amphibian breeding pools may become unsuitable because of increased solar
exposure and change to an unsuitable temperature regime. The amount of edge habitat would
increase, thereby increasing the risk of invasive species establishment and habitat degradation.
Ultimately, early successional plants and wildlife could become established in the converted
area, which subsequently could be maintained over the long term as an emergent or
scrub-shrub wetland in order to avoid vegetation interference with overhead transmission lines.
There would be a net reduction in wetland functions and values due to conversion of forested
wetland to emergent or scrub-shrub wetland (DOE 2019-TN6749; NextEra Energy 2020TN6750). However, the 0.5 ac limit on wetland disturbance renders minimal the potential effects
of wetland habitat conversion, degradation, or fragmentation.

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The staff recognizes that up to 0.5 ac of wetlands can be disturbed by building utility lines in
NWP 12 under the CWA, which the USACE recognizes as not having a significant impact on
waters of the United States (33 CFR 330.1(b); TN4318). The staff assumes that the applicant
would implement any mitigation required by the USACE under the CWA or required by State
agencies that have similar wetland regulatory authority. Even if a project may not require a
permit under the CWA or State wetland protection regulations, the staff expects that applicants
relying on the generic analysis would provide a wetland delineation demonstrating that
assumptions regarding wetlands in the PPE are met. The PPE includes assumptions, based on
information contained in most recent new reactor EISs, that applicants would be required by
State or local governments to implement BMPs as mitigation to minimize sedimentation and
erosion of nearby wetlands. Additionally, because hydrology is one of the most important factors
in the establishment and maintenance of wetlands and wetland processes (SFWMD 1995TN6799), the PPE includes an assumption that licensees relying on the generic analysis would
demonstrate that the assumption regarding the influence of groundwater withdrawal for
dewatering on connected wetlands in the SPE (changes in wetland water levels and
hydroperiod are within historical annual or seasonal fluctuations) is met. If this assumption is not
met, then project-specific analysis would be necessary to demonstrate that impacts would be
minimal. The staff developed this assumption in the PPE based on experience from past
reviews supporting EISs for proposed new reactors in Levy County, Florida (NUREG-1941;
NRC 2012-TN1976) and Berwick, Pennsylvania (NUREG 2179; NRC and USACE 2016TN6562).

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The staff has determined that permanent or temporary loss or degradation of wetlands during
building of a new reactor is a Category 1 issue. The staff concludes that as long as the relevant
assumptions in the PPE and SPE are met, the impacts from building a new reactor can be

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generically determined to be SMALL. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:

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• Applicant would provide a delineation of potentially impacted wetlands, including wetlands
not under CWA jurisdiction.

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• Total wetland impacts from use of the site and any offsite ROWs would be no more than
0.5 ac.

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• If activities regulated under the CWA are performed, those activities would receive approval
under one or more NWPs (33 CFR Part 330) or other general permits recognized by the
USACE.

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• Temporary groundwater withdrawals for excavation or foundation dewatering would not
exceed a long-term rate of 50 gpm.

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• Applicants would be able to demonstrate that the temporary groundwater withdrawals would
not substantially alter the hydrology of wetlands connected to the same groundwater
resource.

• Any required State or local permits for wetland impacts would be obtained.

• Any mitigation measures indicated in the NWPs or other permits would be implemented.

• BMPs would be used for erosion, sediment control, and stormwater management.

3.5.2.1.3 Effects of Building Noise on Wildlife

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Activities to build reactor facilities are usually performed in a series of steps or phases, and
noise associated with different phases can vary greatly depending on the type of equipment
used. Average maximum noise levels of typical building equipment 50 ft from the source may
range from about 73 to 101 dBA for non-impact heavy equipment (earthmoving equipment such
as bulldozers), 79 to 110 dBA for impact equipment (jackhammers, pile drivers, etc.), and 68 to
88 dBA for stationary equipment (pumps, etc.) (WSDOT 2017-TN5313), but an overall noise
level of approximately 85 dBA at 50 ft from the source is typical (DOT 2017-TN5383). Noise
from operating construction equipment can startle and interfere with the behavior and
movement of wildlife. The effects can be exacerbated by the fact that some building noise
occurs episodically rather than continuously over extended periods, and hence wildlife may be
less capable of habituating to it (Shannon et al. 2016-TN6566). A comprehensive literature
review of wildlife responses to anthropogenic noise indicated that some species adversely
respond to noise levels as low as 40 dBA, but 20 percent of the literature documented
responses only above 50 dBA (Shannon et al. 2016-TN6566). Restrictions have been placed on
noise at similar levels within the habitat of sensitive wildlife species. For example, the
U.S. Department of Energy (DOE) considers an increase in noise levels greater than 6 dBA
above ambient to constitute a disturbance to the Mexican spotted owl (Strix occidentalis lucida)
on the Los Alamos Site in New Mexico (Hathcock et al. 2017-TN6789).

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The assumptions in the PPE and SPE include no noise generation greater than 85 dBA at a
point 50 ft from the source. However, noise levels decrease by approximately 6 dBA per
doubling of distance over hard site conditions (i.e., substrate such as concrete or open water) in
accordance with the inverse square law (DOT 2017-TN6567), and by an additional 1.5 dBA
decrease if soft site conditions (e.g., unpacked earth) are present (WSDOT 2017-TN5313).
Therefore, typical building noise of 85 dBA at a distance of only 50 ft from the source may
diminish to only around 50 dBA at about 1,200 ft from the source (assuming soft ground
conditions). This noise level would not generally disturb most wildlife. Furthermore, this value is
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conservative because it likely overestimates the actual noise level because the calculation does
not take into account additional noise attenuation by vegetation and topography (WSDOT 2017TN5313), which are difficult to consider without project-specific analysis.

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The staff therefore expects that potential noise impacts would extend over a sufficiently small
part of the landscape and that any effects on wildlife would be minor and thus be a Category 1
issue. The staff concludes that as long as the assumption in the PPE regarding a maximum
noise generation of 85 dBA 50 ft from the source is met, the impacts can be generically
determined to be SMALL. Effects on wildlife from building noise over 85 dBA would extend over
a greater distance and area and thus require project-specific evaluation. The staff relied on the
following PPE and SPE values and assumptions to reach this conclusion:

• Noise generation would not exceed 85 dBA 50 ft from the source.

3.5.2.1.4 Effects of Vehicular Collisions on Wildlife

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Wildlife can also be killed or injured through collisions with vehicles, although the low number of
construction workers needed to build a reactor of a size fitting the assumptions in the PPE and
SPE suggests that vehicular usage, and hence the potential for collisions, would be minimal.
While roadkill may increase somewhat during the building period, except for special situations
(e.g., ponds and wetlands crossed by roads where large numbers of migrating amphibians
would be susceptible), traffic mortality rates rarely limit population size (Forman and Alexander
1998-TN2250). The potential for significant vehicular collisions with wildlife is limited by the
assumptions in the PPE and SPE regarding site size, size of the footprint of disturbance, and by
limitations on traffic growth, as evidenced by traffic LOSs on roads near the site.

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Federal and State wildlife conservation agencies commonly suggest practices to reduce the
potential for vehicular collisions with wildlife species regarded as regionally sensitive or
desirable. For example, an EIS prepared by the NRC (NRC 2013-TN6436 │ NUREG-2105,
Fermi Unit 3 COL EIS, p. 4-37│) acknowledged the potential for injury and mortality of eastern
fox snakes, a rare (and State-listed) species known to occur near the site, related to
construction equipment while building a proposed reactor, but it also concluded that readily
implemented mitigation measures suggested by the State could prevent noticeable impacts on
the regional population of that species. Some specific mitigation measures proposed included
signage along roads, worker education, and reduced speed limits. Another NRC EIS (NRC
2016-TN6434) recognized the potential for mortality of American crocodiles (a federally listed
threatened species known to inhabit the site and surrounding landscape) by construction vehicle
collisions, but concluded that easily implemented mitigation measures recommended by the
FWS, such as signage and speed limits, could prevent substantial population effects.

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The staff has therefore determined that traffic effects on wildlife are a Category 1 issue. The
staff concludes that as long as the project fits within the PPE regarding site size (no more than
100 ac, with a permanent building footprint of no more than 30 ac and a temporary footprint of
no more than 20 ac) and site employment, the impacts can be generically determined to be
SMALL. The staff relied on the following PPE and SPE values and assumptions to reach this
conclusion:

• The site size would be 100 ac or less.

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• There would be no decreases in the LOS designation for affected roadways.

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• The licensee would communicate with Federal and State wildlife agencies and implement
mitigation actions recommended by those agencies to reduce potential for vehicular injury to
wildlife.

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Mitigation measures that Federal and State wildlife agencies might recommend include the use
of signage, worker education, reduced speed limits where construction equipment crosses
habitat potentially containing regionally rare or declining wildlife, and discussion of these and
other possible mitigation measures with relevant Federal, State, and local conservation offices.

3.5.2.1.5 Bird Collisions and Injury from Structures and Transmission Lines

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Birds and other flying wildlife such as bats can be injured and killed when colliding with tall
structures such as buildings, towers, and transmission lines. The assumptions in the PPE and
SPE are that the tallest building or structure height would be no more than 50 ft, although the
PPE and SPE allow for taller meteorological or communications towers or mechanical draft
cooling towers. Additionally, during construction, cranes that are taller than the structures they
are being used to build may be in place temporarily. It is possible that some birds or bats could
be injured or killed by flying into and colliding with buildings, towers, transmission lines, or
cranes. In the License Renewal GEIS, the NRC reviewed the scientific literature about bird
collisions with buildings and indicated that collisions with buildings and windows account for the
vast majority of annual avian collision mortality in the United States (NRC 2024-TN10161).
Researchers have estimated that the annual mortality rate for each building 1 to 3 stories tall
(approximately 42 ft in height) is about 2 birds and about 16 birds for each building 4 to 11
stories tall (approximately 56 to 154 ft in height) (Loss et al. 2014-TN6568). The PPE assumes,
based on the staff’s experience from recent new reactor EISs and on the scientific literature
cited above, that most buildings and structures developed on smaller new reactor sites would be
less than 50 ft in height, and only a few would be over 50 ft in height (mechanical draft cooling
towers). The low per-building mortality rate for buildings 1 to 3 stories tall plus the 100 ac bound
on the size of the site, which limits and localizes the number of 50 ft or less tall structures,
render negligible the potential for building collision injury and mortality. Although the mortality
rate for each mechanical draft cooling tower is expected to be somewhat higher because of its
greater height (typically 50–100 ft), in the License Renewal GEIS the NRC considered avian
collision mortality from mechanical draft cooling towers to be negligible and therefore did not
address the subject (NRC 2024-TN10161). The staff has determined this conclusion to also be
appropriate for mechanical draft cooling towers on new reactor sites.

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The License Renewal GEIS reviewed the scientific literature about bird collisions with
structures, including nuclear power plant structures, transmission lines, and communication
towers, and evaluated the potential for bird collisions with several operating large LWRs
containing natural draft cooling towers over 400 ft in height and concluded that the effects on
bird populations were minimal (NRC 2024-TN10161). The GEIS found the overall effect from
operating these plants constitutes a small fraction of annual avian collision mortality from all
sources nationwide. The onsite plant structures and communication towers would all be
clustered within the 100 ac site fitting the PPE. For new reactors that meet the assumptions
listed below, the only new transmission lines would likely be those needed to connect the plant
to the regional power distribution system. The assumptions in the PPE and SPE limit the length
of new transmission lines and other offsite linear facilities to less than 1 mi of new ROW not
adjoining existing utilities or roads, and they limit the height of transmission structures (poles or
towers) to no more than 100 ft. The PPE allows for additional co-located transmission line

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ROWs, but co-location would not introduce the potential for collisions to new areas of the
landscape. The transmission lines at such new reactor sites would constitute both a very low
fraction of transmission lines nationwide as well as related collision mortality. Loss et al.
(TN9396) estimated median annual collision rate of about 29.6 birds/km (47.7 birds/mi) of
powerline using strict study inclusion criteria and 23.2 birds/km (37.4 birds/mi) relaxed study
inclusion criteria.

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A new reactor facility within the bounds of the assumptions would have only one or a few towers
or other tall structures clustered on a site of less than 100 ac. METs could be about 197 ft
(60 m) aboveground level (the prescribed height at which wind speed and direction should be
measured), and could be guyed (NRC 2007-TN278). The PPE allows for a single MET of any
height on a site, with non-red, flashing lights if lit. METs (Kerlinger et al. 2012-TN4401), as well
as other types of towers such as communication towers (Longcore et al. 2008-TN4398,
Longcore et al. 2013-TN4399), have been implicated in avian collision mortality of
predominantly neotropical night-migrating songbirds being affected (Longcore et al. 2013TN4399). Estimated rates of avian fatality from collision with ten 50 m (164 ft) and eight 60 m
(197 ft) temporary METs supported by guy wires near wind turbines in central California were
about seven total birds per tower per year, including night-migrating songbirds (Kerlinger et al.
2012-TN4401). Collision mortality increases with increasing tower height; the highest rate of
collision mortality is associated with towers taller than 1,000 ft that use guy wires, and the use of
continuously (as opposed to intermittently) illuminated lights (Longcore et al. 2008-TN4398;
Gehring et al. 2011-TN6581). METs at new reactor sites, regardless of whether they are guyed
or whether or how they may be lit, would cause only negligible avian collision mortality due to
their relatively low height. It is also possible that communication towers could be present on new
reactor sites. Any communication towers would make up only a very minute fraction of all such
towers nationwide and of the collision mortality posed by such towers noted above. The 100 ac
maximum size of the site assumed in the PPE limits the possible number of communication
towers.

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Any effects from buildings, towers, and transmission lines would be localized and not likely to
noticeably contribute to bird mortality in the surrounding landscape. The staff has therefore
determined that bird collisions with structures and transmission lines during building are a
Category 1 issue. The staff concludes that as long as the applicable assumptions in the PPE
and SPE regarding site size and building and structure height are met, the impacts can be
generically determined to be SMALL. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:

• The site size would be 100 ac or less.

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

• No transmission line structures (poles or towers) would be more than 100 ft in height.

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• Licensees would implement common mitigation measures such as those provided by the
American Bird Conservancy (ABC 2015-TN6763) for buildings, by FWS (2013-TN6764) for
towers, and by the Avian Power Line Interaction Committee (APLIC) for transmission lines
(APLIC 2012-TN6779).

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Examples of possible mitigation measures include using building designs that use less glass,
screens and shutters that partly obscure glass, and two-dimensional patterns that birds perceive
as barriers (ABC 2015-TN6763); using unguyed lattice or monopole structures where possible,
keeping towers unlit if the Federal Aviation Administration regulations permit but otherwise using

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flashing (as opposed to steady) lights (FWS 2013-TN6764); marking devices to enhance the
visibility of existing power lines; and considering migratory patterns and high-use areas when
planning new power lines (APLIC 2012-TN6779).

3.5.2.1.6 Important Species and Habitats

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Species and habitats meeting the NRC criteria (NRC 2024-TN7081) for a given site can only be
determined once an application is received that identifies the site boundaries. Because of
differing regulations and sensitivities to impacts, two separate issues are analyzed below
regarding important species and habitats: (1) resources regulated under the ESA (16 U.S.C.
§§ 1531 et seq.; TN1010), and (2) other important species and habitats.

Resources Regulated under the Endangered Species Act of 1973

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The FWS has developed online databases and mapping tools that identify threatened,
endangered, proposed, and candidate species under the ESA, as well as critical habitats
designated and proposed under the Act. Because these federally regulated resources occur in
the same setting and are subject to the same types of impacts as those considered in
Sections 3.5.2.1.1 through 3.5.2.1.5, the limitations placed upon the extent and intensity of
ecological impacts by meeting the assumptions in the PPE and SPE would likewise limit the
potential for impacts on these resources. However, the staff would need to consult individually
with the FWS under ESA Section 7 regarding the potential effects of each specific licensing
action. Furthermore, the criteria for listing species under the ESA are based on the potential for
the most severe of potential ecological impacts: extinction of species, subspecies, or distinct
population segments. Species that have experienced previous impacts so severe that they are
now, or could imminently become, in danger of extinction may also be substantially more
sensitive to impacts that might only pose minimal threat to other species. The staff has therefore
determined that building impacts on resources regulated under the ESA is a Category 2 issue.
Because of their potential for future regulation over the course of a licensing action, the
Category 2 designation extends also to proposed and candidate species and critical habitat
proposed under the Act. Even if the assumptions in the PPE and SPE that are referenced in
Section 3.5.1 are met, the NRC staff is unable to determine the significance of potential impacts
without consideration of project-specific factors, including the specific species and habitats
affected and the types of ecological changes potentially resulting from each specific licensing
action. Furthermore, completing the required consultation requires individualized action by the
staff for each application.

Other Important Species and Habitats

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Most States maintain natural heritage databases that identify known occurrences of species and
habitats receiving various categories of State regulation or recognition. Many species and
habitats that do not display the potential for extinction necessary for regulation under the ESA
are still recognized by States because of declining numbers within State boundaries. However,
extirpation from a State is not as severe an impact as range-wide extinction. Regarding other
types of important species and habitats, most sites containing undeveloped land may support
commercially or recreationally valuable species such as whitetail deer (Odocoileus virginianus),
wild turkey (Meleagris gallopavo), and ring-necked pheasant (Phasianus colchicus), and
nuisance or invasive species such as Canada thistle (Cirsium arvense), johnsongrass
(Sorghum halepense), cheatgrass (Bromus tectorum), European starlings (Sturnus vulgaris),
Burmese pythons (Python bivittatus), and nutria (Myocastor coypus). Research of and
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stakeholders would be necessary to determine other important species and habitats potentially
present on a site, such as species with monitoring requirements, State threatened or
endangered species, other State status species, protected habitats, habitats with high priority
for protection, or other habitats of interest such as nesting or nursery grounds.

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The analyses presented above regarding impacts on terrestrial habitats and wildlife from
specific terrestrial ecological issues suggest that the potential impacts on many important
species and habitats (NRC 2024-TN7081) from building of a new reactor meeting the PPE
and SPE assumptions discussed in Section 3.5.1 would likely be minimal regardless of site
location and the important species specifically present on a given site. The assumptions in
the PPE and SPE limit the potential for adverse impacts, especially limitations on the size of
the footprint of disturbance and the assumed absence of sensitive habitat types
potentially containing rare species within the footprint.

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The staff has therefore determined that building impacts on important species and habitats other
than those regulated under the ESA is a Category 1 issue. The staff concludes that as long as
the assumptions regarding the size and habitat quality within the building footprint, wetlands,
building height, noise generation, and employment in the PPE and SPE are met, the impacts
can be generically determined to be SMALL. The staff relied on the following PPE and SPE
values and assumptions to reach this conclusion:

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• Applicants would communicate with State natural resource or conservation agencies
regarding wildlife and plants and implement mitigation recommendation of those agencies.

3.5.2.2

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The NRC staff identified the following environmental issues for analysis for operation of a new
reactor:

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•
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•
•
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•

Environmental Consequences of Operation

permanent and temporary loss or disturbance of habitats;
effects of operational noise and traffic on wildlife;
exposure of terrestrial organisms to radionuclides;
cooling-tower operational impacts on vegetation;
bird injury and mortality related to collisions with structures and transmission lines;
bird electrocutions by transmission lines;
water use conflicts with terrestrial resources;
effects of transmission line ROW management on terrestrial resources; and
effects of EMFs on flora and fauna.

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In addition to evaluating the issues noted above, the NRC staff addressed as a separate issue
any impacts on important species and habitats as defined for NRC environmental reviews (NRC
2024-TN7081).

3.5.2.2.1 Permanent and Temporary Loss or Disturbance of Habitats

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Substantial losses or changes in habitats on new reactor sites are unlikely during operations,
although small areas of vegetated land might have to be disturbed to maintain, upgrade, or
expand structures or add support structures. In reviewing the environmental effects of operating
large LWRs, the NRC staff explained that most unpaved lands in the developed areas on
nuclear sites are maintained as modified habitats with lawns and other landscaped areas or
may contain early successional habitats (NRC 2024-TN10161). Even if other habitats are
present in developed areas, they can be expected to be small, fragmented, and heavily
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influenced by noise and human activity associated with reactor operations. Based on the
License Renewal GEIS (NRC 2024-TN10161), the NRC staff expects that there would be no
wetlands in such areas, or that any wetland disturbances (except for intake and discharge
structures [Section 3.6.2.1]) would not cause total wetland impacts for the project to exceed the
PPE value of 0.5 ac (Section 3.5.2.1.2). Wetland impacts for projects within the PPE value of
0.5 ac would most likely not require an Individual Permit under CWA Section 404 (33 U.S.C. §
1344-TN1019) and may result from “discharge of dredged or fill material” or other types of
disturbances. The License Renewal GEIS explains that habitats in such settings are generally
tolerant of disturbance (NRC 2024-TN10161), as are associated populations of birds, mammals,
and lizards (Samia et al. 2015-TN6790). Small areas of such habitats could be lost or disturbed
as facilities on the site are refurbished, upgraded, or expanded, although the ecological effects
of any losses on the surrounding landscape are likely to be minimal. Not only would the effects
be minimized because of the limited spatial extent of facilities meeting the PPE, but also
because of the previously altered character of the affected areas.

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The staff has determined that this is a Category 1 issue. The staff concludes that the impacts
can be generically determined to be SMALL. The staff relied on the following PPE and SPE
values and assumptions to reach this conclusion:

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• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation
once the lands are no longer needed to support building activities.

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• The total wetland loss from site disturbance over the operational life of the plant would be no
more than 0.5 ac.

• Any State or local permits for wetland impacts would be obtained.

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• Any mitigation measures indicated in the NWPs or other wetland permits would be
implemented.

• BMPs would be used for erosion, sediment control, and stormwater management.

3.5.2.2.2 Effects of Operational Noise and Vehicular Collisions on Wildlife

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The effects of operational noise and traffic on wildlife would be as described above for building
in Sections 3.5.2.1.3 and 3.5.2.1.4, respectively, but the effects would occur over an extended
period of time covering the operational lifespan of the reactor. Operational noise would tend to
be lower in intensity and steadier than building noise, and wildlife may therefore be better able
to habituate to and tolerate the noise. As for during construction, the potential for injury or
mortality of wildlife caused by vehicular collisions would be limited by the low employment at the
reactor established in the PPE. Furthermore, it is unlikely that new roads would be constructed
through substantial blocks of natural habitat thereby exposing additional wildlife to noise or
collision threats during operations. The staff has therefore determined that operational noise
and traffic are Category 1 issues. The staff concludes that as long as the applicable
assumptions in the PPE and SPE regarding noise generation and employment are met, the
impacts can be generically determined to be SMALL. The staff relied on the following PPE and
SPE values and assumptions to reach this conclusion:

• Noise generation would not exceed 85 dBA 50 ft from the source.

• There would be no decreases in the LOS designation for affected roadways.

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• The licensee would communicate with Federal and State wildlife agencies and implement
mitigation actions recommended by those agencies to reduce potential for vehicular injury to
wildlife.
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3.5.2.2.3 Exposure of Terrestrial Organisms to Radionuclides

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The NRC staff recognizes that small amounts of radioactive particulates can be vented to the
exterior environment during operation of LWRs and evaluated the potential effects of those
releases on terrestrial ecological receptors in the License Renewal GEIS (NRC 2024-TN10161).
Section 3.8.1.2.2 of this GEIS concludes that the impact of routine radiological releases from
past and current operations on terrestrial biota would be SMALL. To support that conclusion,
Table 3-6 (in Section 3.8.1 in this GEIS) presents radiological exposure estimates for two
mammal and two bird species modeled using NRCDose code, as presented in 15 EISs for
proposed new LWRs published between 2006 and 2019. All estimates were substantially lower
than exposure levels considered protective of terrestrial animal populations by the International
Atomic Energy Agency (IAEA).

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In the License Renewal GEIS (NRC 2024-TN10161), the staff also used the RESRAD-BIOTA
dose evaluation model developed by DOE (DOE 2004-TN6460) to calculate estimated dose
rates to terrestrial biota receptors using REMP reports submitted by licensees for 15 operating
LWRs in the United States. RESRAD-BIOTA accounts for bioaccumulation of radionuclides in
the tissues of biological organisms and biomagnification, whereby radionuclides become
concentrated at higher levels in organisms occupying higher positions in the food chain. The
staff calculated estimated doses for three terrestrial ecological receptors: riparian animals
(animals estimated to spend approximately half their time in aquatic environments and half in
terrestrial environments), terrestrial animals, and terrestrial plants. None of the estimated doses
exceeded levels recognized by DOE as being protective of riparian or terrestrial animals
(0.1 rad/d [0.001Gy/d]) or terrestrial plants (1.0 rad/d [0.01 Gy/d]) (DOE 2002-TN4551).

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• While many new reactors may use fuels containing different compositions of radionuclides
than the LWRs considered in the analyses presented above, a reactor meeting the PPE for
Radiological Environmental Hazards in Appendix G would not be likely to result in greater
releases of radioactivity. The staff has determined that this is a Category 1 issue. The staff
concludes that as long as the assumptions in the PPE underlying the analysis in Section 3.8
are met, the impacts can be generically determined to be SMALL without mitigation. The
staff relied on the following PPE and SPE values and assumptions to reach this conclusion:

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• Applicants would demonstrate in their application that any radiological nonhuman biota
doses would be below IAEA (1992-TN712) and National Council on Radiation Protection
and Measurements (NCRP) (1991-TN729) guidelines.

3.5.2.2.4 Cooling-Tower Operational Impacts on Vegetation

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The PPE assumes that a new reactor would use only fresh makeup water that has a salinity of
under 1 ppt for operation of any cooling towers. The staff has found in past new reactor EISs
that salt drift modeling sometimes indicates potentially significant impacts on vegetation when
brackish water is used as makeup water (NRC 2012-TN1976, NRC 2016-TN6434, NRC 2016TN6840). The PPE also assumes that any cooling towers would be the mechanical draft type
rather than natural draft cooling towers and under 100 ft in height. While mechanical draft
cooling towers are typically under 100 ft in height, natural draft cooling towers can be more than
400 ft in height. Natural draft towers release drift higher into the atmosphere and therefore can
spread drift farther across the landscape than can mechanical draft towers. Drift from
mechanical draft towers tends to affect only vegetation in close proximity to the towers, which is
mostly limited to disturbed lawns and other successional vegetation typical of existing
industrially developed areas. The PPE also assumes that any cooling towers would be equipped
with drift eliminators to minimize the amount of drift.

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The NRC staff recognizes that salt deposition rates between 1 and 2 kg/ha/mo are generally not
damaging to plants, while rates approaching or exceeding 10 kg/ha/mo in any month during the
growing season could cause leaf damage in many species (NRC 2000-TN614). Even
10 kg/ha/mo is a conservative estimate representing documented acute injury only of the most
sensitive of crop and native vegetation plant species (NRC 1996-TN288). It is reasonable to
expect that substantially higher deposition rates would be needed to cause noticeable injury to
vegetation consisting of a mixture of plant species of differing sensitivities.

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Estimates for TDS (total dissolved solids, referred to hereafter as “salt”) deposition rates were
less than 10 kg/ha/mo for several recently completed new reactor EISs where mechanical draft
cooling towers were to be operated using fresh makeup water. Estimates for maximum salt drift
deposition from operation of four mechanical draft cooling towers serving the proposed
Comanche Peak Units 3 and 4 in inland Texas were approximately 3.49 kg/ha/mo, at a point
100 m (328 ft) north of the towers (NRC 2011-TN6437). Estimates for maximum salt drift
deposition from operation of four mechanical draft cooling towers serving the proposed William
States Lee Units 1 and 2 in western South Carolina were 0.0103 kg/ha/mo, at a point 200 m
(656 ft) north of the towers (NRC 2013-TN6435). The estimates for building SMRs of
unspecified technology at the Clinch River site in Oak Ridge, Tennessee, were as high as
112.7 kg/ha/mo at a point approximately 100 m (328 ft) from the towers but were less than
10 kg/ha/mo at 300 m (984 ft) from the towers. Even though the Clinch River data suggest
possible vegetation damage in close proximity to operating mechanical draft cooling towers,
such close-in areas to a nuclear power plant are usually industrial in character and any
vegetation present would likely be ruderal or highly disturbed vegetation of low ecological value.
The low estimated drift rate for areas 1,000 ft from the towers suggests that the potential effects
of vegetation damage on the surrounding landscape would be low.

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There is less of a record to draw from for cooling towers operated using brackish water or
seawater makeup sources. The maximum deposition for the proposed Turkey Point Units 6 and
7, which were modeled using mechanical draft cooling towers with makeup water as salty as
seawater, was estimated to be as high a 105 kg/ha/mo close to the towers (NRC 2016-TN6434)
but to diminish rapidly with distance to under 10 kg/ha/mo within 1 mi from the towers
(NRC 2016-TN6434). Although the Turkey Point EIS concluded that the effects would be
minimal, the proposed site was situated on an island with an existing nuclear plant where the
nearest high-quality natural habitat was nearly 1 mi distant (NRC 2016-TN6434). Had
high-quality natural habitats been present close to those reactors, habitat function could have
been noticeably compromised due to leaf injury. The maximum deposition for the proposed
Levy Units 1 and 2 in north-central Florida, which was to use natural draft cooling towers with
brackish makeup water of about 24 ppt, was estimated to be 10.75 kg/ha/mo (NRC 2012TN1976). Such deposition suggests the possibility of noticeable leaf damage in terrestrial
habitats close to the site. The Levy plant, however, was designed with natural draft cooling
towers, which tend to disburse drift farther from the towers than mechanical draft towers.

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The NRC staff recognizes that damage to forested habitats can result from icing of
cooling-tower drift but recognizes such damage as being “rare, minor, and localized” (NRC
2024-TN10161). The recently completed new reactor EISs discussed above dismiss the effects
of icing on terrestrial habitats from cooling-tower operation as being minimal. Even in arctic or
very cold habitats, the existing vegetation would have to already be adapted to heavy snow and
ice accumulation.

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The staff has determined that cooling-tower effects on vegetation are a Category 1 issue. The
staff concludes that as long as the applicable assumptions regarding cooling towers in the PPE

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and SPE are met, including that the source of makeup water is fresh (salinity of less than 1 ppt),
the impacts can be generically determined to be SMALL. The staff relied on the following PPE
and SPE values and assumptions to reach this conclusion:

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• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in
height; and equipped with drift eliminators.

• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).

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The staff recognizes that vegetation damage from the operation of cooling towers using
brackish water or seawater as makeup water may also have a low probability of noticeable
adverse effects on terrestrial habitats, but less evidence is available to support high confidence
in that conclusion without completion of project-specific analysis.

3.5.2.2.5 Bird Collisions and Injury from Structures and Transmission Lines

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The structures and transmission lines discussed in Section 3.5.2.1 for building would continue to
be present during operations, and no new structures or transmission lines would be introduced
during operations that were not previously considered. Thus, the analyses in Section 3.5.2.1
also apply during operations. As for construction, the staff has determined that bird collisions
with structures and transmission lines during operations are a Category 1 issue. The staff
concludes that as long as the assumptions regarding structure heights and transmission lines
are met, the impacts can be generically determined to be SMALL. The staff relied on the
following PPE and SPE values and assumptions to reach this conclusion:

• The site size would be 100 ac or less.

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

• No transmission line structures (poles or towers) would be more than 100 ft in height.

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See Section 3.5.2.1.5 for a brief discussion of the types of possible mitigation measures.

3.5.2.2.6 Bird Electrocutions from Transmission Lines

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The potential for avian electrocutions from energized transmission conductors depends on a
combination of biological, environmental, and electrical design factors (APLIC 2006-TN794).
Biological and environmental factors include proximate habitat, bird species (body size,
behavior, distribution, and abundance), and prey availability. The key electrical design factor is
the physical separation between energized conductors (wires). If the distance between
energized conductors is less than that of the head-to-foot or wrist-to-wrist distance of a bird,
electrocution may occur. APLIC (2006-TN794) recommends that conductors be spaced a
minimum of 60 in. apart horizontally and 40 in. apart vertically, with 60 in. vertical separation
recommended near sensitive avian habitats. Contact between a single conductor and a bird
does not generally result in electrocution, but simultaneous contact by a bird with more than one
conductor (or air space very close to a conductor) can cause electrocution because of the
phase differences in voltage. Most electrocutions are of birds that have large wingspans, such
as eagles, hawks, vultures, ravens, and large waterbirds. Of particular concern are bald eagles
(Haliaeetus leucocephalus) and golden eagles (Aquila chrysaetos), which are protected under

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the Bald and Golden Eagle Protection Act (16 U.S.C. §§ 668 et seq.; TN1447) (APLIC and EEI
2018-TN6809). Although collisions occur at both distribution lines and transmission lines,
electrocutions mostly occur at distribution lines, with voltages between 2.4 and 60 kV (Loss
et al. 2014-TN9396). Electrocution mortality is not known to have been a concern at existing
nuclear power plants in the United States; thus, the NRC did not address the subject in its
License Renewal GEIS (NRC 2024-TN10161).

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The staff expects the likelihood of avian electrocution mortality, up to and including population
level effects, would be low for new reactor transmission lines in any environmental setting and
has concluded this is a Category 1 issue. As long as the assumptions regarding transmission
lines in the PPE and SPE are met, the impacts can be generically determined to be SMALL.
The staff relied on the following PPE and SPE values and assumptions to reach this conclusion:

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• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than
100 ft in width and total no more than 1 mi in length.

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• Common mitigation measures, such as those recommended by APLIC (2006-TN794), would
be implemented.

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The potential for electrocutions is limited by the PPE that assumes a maximum of 1 mi of ROW
not co-located with existing ROWs or roads. APLIC (2006-TN794) recognizes that co-location of
new power lines with existing power lines reduces the potential for electrocutions. The greatest
potential for electrocutions is where power lines cross open treeless areas (APLIC and EEI
2018-TN6809), but even in these areas the limitations assumed under the PPE are expected to
keep impacts at low significance. Examples of mitigation measures recommended by APLIC
include separation of phase conductors and grounded hardware, and installation of covers on
phases or grounds where adequate separation is not feasible (APLIC 2006-TN794). Moreover,
most electrocutions are on distribution lines, not transmission lines (Loss et al. 2014).

3.5.2.2.7 Water Use Conflicts with Terrestrial Resources

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Water levels and hydroperiod are important factors in determining the composition of wetland
plant and animal species present (EPA 1996-TN6800; SFWMD 1995-TN6799). Through
physiological stress and habitat alteration, water-level fluctuations create temporal and spatial
heterogeneity that shapes littoral zone (shoreline and nearshore) habitats. Freshwater littoral
zones typically harbor diverse ecological communities that serve numerous ecosystem functions
that are influenced, in part, by water-level fluctuations (Carmignani and Roy 2017-TN6795). For
example, some native plants and animals have adapted to the range of hydrologic conditions
that occur in natural wetlands (SFWMD 1995-TN6799).

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Large anthropogenic water withdrawals can influence the water levels and hydroperiod in
wetlands, floodplains, riparian, and other terrestrial habitats connected to flowing water bodies;
non-flowing freshwater, brackish, and marine water bodies; and groundwater sources supplying
water to meet the demands. Adverse effects on these habitats can occur when the water levels
or hydroperiod are changed beyond historical annual or seasonal fluctuations. In the License
Renewal GEIS, which addresses large LWRs operating as of 2013 that typically use
water-based cooling systems requiring large quantities of water, the NRC staff concluded that
project-specific analyses were necessary to characterize the potential impacts from water use
conflicts on terrestrial habitats (NRC 2024-TN10161).

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Flowing Water Bodies

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The staff’s assumption regarding surface water availability for flowing systems (i.e., withdrawals
from rivers under low flow conditions of less than or equal to 3 percent of the 95 percent
exceedance flow, or extreme low flow conditions) would result in the loss of an even much
smaller percentage of the full or out-of-bank flows typically required to maintain riparian habitats
and connected wetlands, floodplains, and riparian areas (Hill et al. 1991-TN6791; Navratil 2006TN6792; Poff et al. 1997-TN6794; Kendy et al. 2012-TN6793). The 95 percent exceedance flow
accounts for cumulative hydrologic impacts because it includes existing withdrawals and
planned future withdrawals. Although there are no standard metrics for determining the flow
quantity or duration needed to maintain wetland, floodplain, and riparian habitats (Hill et al.
1991-TN6791), a minor water withdrawal such as 3 percent of the 95 percent exceedance flow
is unlikely to reduce water levels or alter hydroperiods in such habitats enough to cause
noticeable adverse effects, even when added to existing or planned water withdrawals. If the
low flow withdrawal assumption is not met, project-specific analysis would be required to
determine potential impacts on connected wetland, floodplain, and riparian habitats.

Non-flowing Water Bodies

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Human activities that reduce lake water levels and hydroperiods below historical annual or
seasonal fluctuations may threaten littoral zone ecological integrity (Carmignani and Roy 2017TN6795; SFWMD 1995-TN6799) as described above for withdrawals from flowing water bodies.
Freezing or drying out of root systems and compaction of sediment may stress emergent and
aquatic plants. Reduced plant productivity, cover, and food supplies may result in a decrease in
dependent microorganisms, invertebrates, fish, and wildlife. Forage species that supply food for
birds and other wildlife might be replaced by species more tolerant of desiccation and/or
freezing, thereby having detrimental ecological effects on existing communities. For example, a
U.S. Bureau of Reclamation EIS (USBR 2004-TN6796) evaluated a proposed 5 ft drawdown of
Banks Lake in eastern Washington State lasting up to 2 months and concluded that there would
be adverse impacts on the distribution of vegetation, fish, and wildlife; prompting the U.S.
Bureau of Reclamation to propose vegetation mitigation and further investigate potential effects
on wildlife. Flat, shallow habitats are anticipated to incur greater areal exposure than steeper
habitats during a given drawdown.

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The staff assumes a maximum surface water use rate of 6,000 gpm (Section 3.4.1) for total
plant water demand, applying to non-flowing water bodies such as the Great Lakes, the Gulf of
Mexico, oceans, estuaries, and intertidal zones. The staff assumes for the generic analysis that
the quantity of surface water withdrawn from these water bodies would not result in a reduction
in water levels or hydroperiod that could adversely affect connected wetlands, floodplains, or
riparian or other habitats. However, for other non-flowing bodies of freshwater (e.g., inland
lakes, ponds, and reservoirs) the staff assumes that applicants relying on the generic analysis
would demonstrate that the assumption regarding connected wetlands, floodplains, or riparian
habitats (changes in water levels and hydroperiod are within historical annual or seasonal
fluctuations) is met. If the applicant cannot so demonstrate, project-specific analysis would be
necessary to determine potential impacts on connected wetland, floodplain, and riparian
habitats. Such a demonstration would only be necessary if the site contains more than just low
value wetlands or other terrestrial habitats, such as drainage ditches or manufactured
depressions within uplands, or dominated by invasive vegetation.

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Estuaries and Intertidal Zones

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Water withdrawals from brackish non-flowing water bodies such as estuaries (partially enclosed,
coastal water body where freshwater mixes with marine water) could affect connected terrestrial
habitats and wildlife due to potential changes in water quality. Many different terrestrial habitat
types are found in estuaries, including freshwater and saltwater tidal marshes, tidal swamps,
sandy beaches, mud and sand flats, rocky shores, mangrove forests, and river deltas. The most
influential gradient in estuaries is salinity because it structures the spatial patterns of physical
properties, biogeochemical processes, and plants and wildlife with species-specific adaptations
to different salinity ranges (Cloern et al. 2017-TN6967). The salinity gradient in such settings
depends on the relative exchanges of both fresh and marine water, which may be altered
beyond historical annual or seasonal fluctuations by withdrawal of either fresh or marine water
(40 CFR 230.25; TN427). Water withdrawals in estuaries may alter both the physical extent of
saltwater influence and salinity levels and thereby affect populations of salinity-dependent food
sources that could in turn affect the survival of dependent wildlife. The staff therefore assumes
that applicants relying on the generic analysis would demonstrate that the assumption for
estuaries regarding connected terrestrial habitats (changes in the physical extent of saltwater
influence and salinity gradients are within historical annual or seasonal fluctuations) is met. If
the assumption is not met, further project-specific analysis would be necessary to determine
potential impacts on the physical extent of saltwater influence and salinity gradients as well as
associated food chain effects.

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Water withdrawals from marine or brackish non-flowing water bodies such intertidal zones (area
of shoreline between low and high tides) could affect habitat and wildlife due to potential
changes in water quality. Intertidal zones can encompass terrestrial habitats such as sandy
beaches, mud and sand flats, and rocky shores. Intertidal zones are characterized by unique
environmental conditions, including variable temperatures (depending on the status of the tide),
microclimates, and ecological factors that provide habitat for a wide variety of plant and animal
species. The vulnerability of intertidal zones to water withdrawals depends to a large extent on
the degree of enclosure from the open ocean. Partially enclosed intertidal zones with little
connectivity or current exchange with the open ocean would be more susceptible to water
withdrawals affecting salinity gradients than intertidal zones that are more open and connected
to the ocean. The irregularity in the geomorphology of coastal environments in terms of the
vertical and horizontal degree of enclosure from the open ocean varies widely, as does the
degree of vulnerability of intertidal zones to the effects of water withdrawal on changes in
salinity levels. The staff therefore assumes that applicants relying on the generic analysis would
demonstrate that the assumption for intertidal zones (changes in salinity levels are within
historical annual or seasonal fluctuations) is met. If the assumption is not met, further projectspecific analysis would be required to determine potential impacts on salinity gradients as well
as associated habitat and food chain effects.

Groundwater

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The water use assumptions established in the PPE and SPE for surficial groundwater depletion
that could influence terrestrial habitats include withdrawal of less than or equal to 50 gpm
resulting in drawdown of no more than 1 ft at the site boundary. Withdrawals of surficial
groundwater during plant operations would be continual and thus have the potential for
permanent impacts on connected terrestrial habitats. Localized shoreline habitats throughout
the United States and internationally have undergone changes consistent with a loss or
reduction of groundwater discharge (EPA 1996-TN6800). High-risk hydrologic settings include
groundwater-fed wetlands without a surface water connection (EPA 1996-TN6800; MBWSR

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2016-TN6801), such as many prairie potholes, pocosins, peat bogs, fens, and Carolina bays.
Long-term lowering of groundwater levels may impact groundwater-fed isolated wetlands in
much the same way as surface water withdrawals (described above for flowing and non-flowing
water bodies), but very few studies provide quantitative analysis. Some data suggest that
chronic reductions of groundwater levels result in a reduction in hydroperiod and can have
significant effects on plant community structure in wetlands (SFWMD 1995-TN6799). A less
than 1 ft modeled drawdown of groundwater has been shown to be associated with actual
drawdowns of several feet in isolated wetlands, and an extended modeled drawdown of
groundwater from 0.6 to 1.0 ft, within seasonally to semi-permanently flooded isolated wetlands,
has been shown to correspond with significant changes in plant community composition and
structure (SFWMD 1995-TN6799). Thus, there was ample evidence that a drawdown criterion of
less than 1 ft may be appropriate in some areas of Florida (SFWMD 1995-TN6799). However,
most of the studies reviewed by the South Florida Water Management District (SFWMD 1995TN6799) did not establish a threshold of harm corresponding to specific groundwater drawdown
level (modeled or actual).

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Desert springs, often the sole sources of water for some wildlife in the arid west, often support
wetland and wetland/upland transition ecosystems including rare and endemic species.
Groundwater withdrawal may lower the local water table, reducing the areal cover of wetland
and wetland/upland transition vegetation and reduce the amount of upland phreatophytic
vegetation (deep-rooted plants that obtain water from the water table or the layer of soil just above
it) by causing water levels to drop below plant rooting depths. Percolation of salts to surface
soils may be reduced, eventually altering desert shrub cover from halophytes (plants adapted to
growing in saline conditions) to nonhalophytes. The extent of these effects will vary among
springs, based on their distance from groundwater extraction sites and location relative to
regional groundwater flow paths (Patten et al. 2007-TN6968). For example, outflow distance at
springs that have low discharge rates generally may not be more than 200 m, while outflow
distance at springs that have large discharges can be many kilometers (Patten et al. 2007TN6968).

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Based on the above information related to the extraction of surficial groundwater, the staff has
no assurance that relying on assumed PPE/SPE values of groundwater drawdown of no more
than 50 gpm and no more than 1 ft at the site boundary, would adequately protect wetlands with
a groundwater connection, either within or outside of the site boundary. Based on these
analyses, even for a new reactor bounded by the assumptions for groundwater withdrawals for
dewatering in the PPE and SPE (50 gpm with no more than a 1 ft drawdown of groundwater
levels at the site boundary), some onsite and offsite wetlands in certain settings with a
groundwater connection could be affected. Adverse impacts on onsite and offsite wetlands
could result if groundwater dewatering causes changes in water levels or hydroperiod that
exceed historical annual or seasonal fluctuations. This applies to wetlands with a groundwater
connection but may be accentuated in such wetlands without a surface water connection. The
staff expects that applicants relying on the generic analysis would demonstrate that the
terrestrial resources assumption regarding wetlands (changes in water levels and hydroperiod
are within historical annual or seasonal fluctuations) in the SPE is met. It might be possible to
demonstrate that there are no wetlands, or only wetlands of minimal value, present on or in the
immediate vicinity of the site. Or it might be possible to demonstrate that the only wetlands on or
near the site belong to hydrogeomorphic classes not typically influenced by groundwater, such
as the hydrogeomorphic classes of riverine wetlands or tidal or lacustrine fringe wetlands
(Brinson et al. 1995-TN6969). Other tools might be available from various regulatory agencies
or other institutions and could be used. Such a demonstration would also have to provide

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evidence that the maximum depth to groundwater lay substantially below the surface. If this
assumption is not met, further project-specific analysis would be required.

Conclusion

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The staff has determined that water use conflicts with terrestrial resources are a Category 1
issue under the assumptions discussed above for flowing water bodies, non-flowing water
bodies (including freshwater, brackish, and marine), and surficial groundwater. If the applicable
assumptions for terrestrial resources in the relevant water body type are not met,
project-specific analyses would be necessary to characterize potential impacts on habitats
connected to such water bodies as well as on dependent wildlife. The staff relied on the
following PPE and SPE values and assumptions to reach this conclusion:

• Total plant water demand would be less than or equal to a daily average of 6,000 gpm.

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• If water is withdrawn from flowing water bodies, average plant water withdrawals would not
reduce flow by more than 3 percent of the 95 percent exceedance daily flow, and would not
prevent maintenance of applicable instream flow requirements.

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• Any water withdrawals would be in compliance with any EPA or State permitting
requirements.

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• Applicants would be able to demonstrate that hydroperiod changes are within historical or
seasonal fluctuations.

3.5.2.2.8 Effects of Transmission Line ROW Management on Terrestrial Resources

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Once a transmission line is built, ROWs in potential forest habitat will require routine
maintenance to keep them free of trees tall enough to cause electrical current to arc through
vegetation to the ground, which may ignite fires and cause power outages. It may also be
necessary to trim or remove trees growing near the edge of the ROW that are capable of falling
too close to the conductors (commonly termed “danger trees”). Trimming or removing individual
danger trees is unlikely to substantially alter the ecological properties of terrestrial habitats
adjoining the ROW. Some utilities also maintain “screens” of low trees under transmission line
conductors where they cross aesthetically sensitive suburban roadways; those tree screens
require frequent maintenance. The ecological properties of the screens are unlikely to be
substantially altered by trimming the entire screen or by removal of individual trees. Sometimes
relatively level upland areas on transmission line ROWs, especially in aesthetically sensitive
residential areas, are periodically mowed. But the most common techniques used in managing
transmission line ROWs involve the use of herbicides. Herbicides can be applied directly to
vegetation in the ROW, or herbicides can be applied to cut stump surfaces once trees are felled.

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The NRC staff performed a comprehensive literature review of the potential effects of
transmission line ROW management on terrestrial resources as part of the License Renewal
GEIS (NRC 2024-TN10161). The analysis considered various common ROW management
practices including tree trimming and clearing, mowing, and herbicide application and concluded
that the overall ecological effects were neither substantially adverse nor beneficial. Limitations
on the length and routing of transmission lines in the PPE further reduce the potential for
adverse impacts.

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The staff has determined that this is a Category 1 issue. The staff concludes that as long as the
assumptions regarding transmission lines in the PPE and SPE are met, the impacts can be
generically determined to be SMALL. The PPE includes an assumption that licensees would

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implement integrated vegetation management practices to maintain ROWs in areas where
vegetation growth may interfere with power lines. Mitigation measures necessary to rely on the
generic analysis include ensuring that all work is performed in compliance with all applicable
laws and regulations and that herbicides are applied only by licensed applicators in compliance
with the applicable manufacturer label instructions. The staff relied on the following PPE and
SPE values and assumptions to reach this conclusion:
• Vegetation in transmission line ROWs would be managed following a plan consisting of
integrated vegetation management practices.

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• All ROW maintenance work would be performed in compliance with all applicable laws and
regulations.

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• Herbicides would be applied by licensed applicators, and only if in compliance with
applicable manufacturer label instructions.

3.5.2.2.9 Effects of Electromagnetic Fields on Flora and Fauna

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Electric current moving through transmission lines generates an EMF in the surrounding
airspace. The NRC staff performed a comprehensive literature review of the potential effects of
EMFs on terrestrial resources, including flora, honeybees, and wildlife and livestock and
identified no significant impacts (NRC 2024-TN10161). Based on the literature review in the
License Renewal GEIS, the staff determined that this is a Category 1 issue and impacts would
be SMALL regardless of the length, location, or size of the transmission lines. The staff did not
recommend any mitigation in the License Renewal GEIS (NRC 2024-TN10161); hence, none is
needed here. The staff did not rely on any PPE and SPE values or assumptions in reaching this
conclusion.

3.5.2.2.10 Important Species and Habitats

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As noted for building, important species and habitats meeting the NRC criteria (NRC 2024TN7081) for a given site can only be determined once the site is identified. Because of different
regulations and sensitivities to impacts, two separate issues are analyzed below regarding
important species and habitats: (1) resources regulated under the ESA (16 U.S.C.
§§ 1531 et seq.; TN1010), and (2) other important species and habitats.

Resources Regulated under the Endangered Species Act of 1973

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For the same reasons noted for building in Section 3.5.2.1.6, the staff has determined that
operational impacts on resources regulated under the ESA are a Category 2 issue. Because of
their potential for future regulation over the course of a licensing action, the Category 2
designation extends also to candidate species and species and critical habitat proposed for
designation under the Act. Even if the applicable assumptions in the PPE and SPE outlined in
Section 3.5.1 are met, the NRC staff is unable to determine the significance of potential impacts
without consideration of project-specific factors, including the specific species and habitats
affected and the types of ecological changes potentially resulting from each specific licensing
action. Furthermore, completing the required consultation requires individualized action by the
staff for each application.

Other Important Species and Habitats

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The analyses presented in Section 3.5.2.1.6 also apply to operations and suggest that the
potential impacts on other important species and habitats as defined in RG 4.2 (NRC 20243-81

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TN7081) from operating a new reactor that meets the PPE and SPE would likely be minimal
regardless of site location and the important species specifically present on a given site. The
assumptions in the PPE and SPE limit the potential for adverse impacts, especially limiting the
size of the disturbance footprint and the assumed absence of sensitive habitat types potentially
containing rare species within the footprint. The staff has therefore determined that operational
impacts on important species and habitats other than those regulated under the ESA are a
Category 1 issue. The staff concludes that as long as the applicable assumptions regarding the
size and habitat quality of the building footprint, wetlands, building height, noise generation, and
employment in the PPE and SPE are met, the impacts can be generically determined to be
SMALL. The staff relied on the following PPE and SPE values and assumptions to reach this
conclusion:

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• Applicants would communicate with State natural resource or conservation agencies
regarding wildlife and plants and implement mitigation recommendation of those agencies.

3.6

Aquatic Ecology

3.6.1

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Some sites proposed for a new reactor may include (or be adjacent to) aquatic habitats in
streams, rivers, ponds, lakes, or other surface water features. Other sites may lack aquatic
habitats within their perimeters, but activities there could still affect aquatic habitats because the
sites lie in the watershed, thereby contributing overland runoff to down-gradient surface water
features containing aquatic habitats. Some watersheds may drain directly to large bodies of
waters such as oceans, estuaries, or large lakes; while others may instead drain into tributary
systems that flow into the larger bodies of water. In some landscapes, sites may drain into
depressions where the accumulated water forms permanent or temporary lakes or ponds, or
ephemeral features such as playas and vernal pools, from which it evaporates to the
atmosphere or leaches into the groundwater. In landscapes overlying limestone (karst
landscapes), sites may drain into streams whose flow disappears into the underlying
groundwater and may emerge at springs elsewhere in the landscape.

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The separation between aquatic and terrestrial habitats is not always sharp; the edges of some
aquatic habitats are clearly bounded by an ordinary high-water mark, while elsewhere the
transition is gradual and may include interim zones of wetlands. The NRC staff typically
considers wetlands that contain persistent emergent vegetation, including most swamps and
marshes, to be terrestrial habitats (addressed in Section 3.5), while considering wetlands
dominated only by submerged aquatic vegetation to be aquatic habitats (NRC 2024-TN7081).
More information about how the NRC staff defines and characterizes aquatic habitats is
available in RG 4.24 (NRC 2017-TN6720).

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Aquatic habitats may be marine, estuarine, or freshwater. Marine habitats in oceans or bays
broadly open to the ocean generally are saltwater, with a typical seawater salinity of
approximately 35–37 ppt. Seawater that accumulates in depressions may attain higher salinities
due to partial evaporation. Estuaries are surface water areas where freshwater entering through
tributaries or runoff mixes with seawater carried by the tides, resulting in brackish water
between 0.5 ppt and less than 35 ppt. Estuarine habitats are typically in continuous flux in
response to changing tides, freshwater inflow, and freshwater runoff. Freshwater habitats, with
salinities generally 0.5 ppt or less, are sometimes characterized as either lotic, situated in
portions of streams or rivers containing running water; or lentic, situated in ponds, lakes, or
portions of streams or rivers containing standing water. Biota at the base of aquatic food chains

Baseline Conditions and PPE/SPE Values and Assumptions

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are photosynthetic (capable of using sunlight to produce biomass); including photosynthetic
bacteria, phytoplankton (free-floating microscopic algae), larger floating algae or algae fixed to
solid substrates by holdfasts or rooted submerged vascular plants. Other components of the
aquatic food chain can include zooplankton (free-floating microscopic animal-like biota), benthic
organisms (generally larval insects or other fauna that attach to rocks and other solid
underwater substrates), fish, crustaceans, and shellfish. Many fish and shellfish include
microscopic life stages that behave more like plankton than the independently mobile adults.
The aquatic food chain is intimately connected to the terrestrial food chain and can be
influenced by terrestrial organisms such as birds, mammals, reptiles, amphibians, and insects.

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The NRC staff developed the values and assumptions in the PPE and SPE pertaining to aquatic
ecology based on the information and analyses contained in multiple new reactor EISs prepared
since 2005, the License Renewal GEIS (NRC 2024-TN10161), other past NRC EISs, and
Federal and State regulations protecting waters of the United States and threatened and
endangered species.

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Based on experience gained from preparing past new reactor EISs, the NRC staff included an
assumption in the PPE and SPE that permanent disturbance would encompass no more than
30 ac of vegetated land, with temporary disturbance of as much as an additional 20 ac of
vegetated land. The NRC staff also assumes the temporarily disturbed land will be restored
once it is no longer needed using regionally indigenous vegetation. Disturbances to land in the
watershed of surface water bodies can result in sedimentation and stormwater runoff reaching
habitats of aquatic flora and fauna. The NRC staff would have to consider project-specific
factors if greater disturbances were necessary. Also, based on the staff’s experience with past
new reactor EISs, the PPE and SPE additionally assume that the footprint of disturbance (other
than for building intake or discharge structures) would not encompass aquatic habitats.
However, as explained in Section 3.5.1, the assumptions in the PPE and SPE allow for impacts
on as much as 0.5 ac of wetlands or other waters of the United States, based on disturbance
area limits built into several NWPs established by the USACE under Section 404 of the CWA
(33 U.S.C. § 1344-TN1019). The PPE and SPE also recognize that transmission lines,
pipelines, and access roads might extend across or under streams or small surface water
features (as long as the project’s total impact on wetlands and other surface water bodies is less
than 0.5 ac).

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Recognizing that the evaluation of aquatic impacts in the License Renewal GEIS (NRC 2024TN10161) and past new reactor EISs identified substantial impacts from certain types of plant
cooling systems, the staff included an assumption in the PPE and SPE that allows for use of
recirculated-water cooling towers, but not once-through cooling systems, cooling ponds, or new
cooling-water reservoirs. However, the assumptions still recognize that any cooling towers
would have to be mechanical draft type rather than natural draft type, and that any makeup
water for cooling would have to be fresh (salinity less than 1 ppt). EISs for proposed new
reactors in Levy County, Florida (NRC 2012-TN1976) and Homestead, Florida (NRC 2016TN6434) identified potentially damaging salt drift at certain locations close to cooling towers
using brackish makeup water. The PPE and SPE also assume that any intake would meet the
requirements established by the EPA in 40 CFR 125.83 (TN254) for protection of aquatic biota
from entrainment or impingement. Because of the potential for contamination by dissolved
metals in cooling-system blowdown water that are toxic to aquatic biota, the PPE also assumes
no use of copper alloy tubes in cooling systems. Based on information in past new reactor EISs,
the staff established assumptions in the PPE and SPE regarding features such as transmission
lines and other linear utilities. The PPE and SPE assume that any new poles or towers would be
built outside of wetlands and floodplains and that any pipelines would be directionally drilled

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under surface water features such as streams without disturbance to shorelines or bottom
substrates. Finally, the PPE and SPE assumptions relevant to aquatic ecology include all of the
assumptions developed for Hydrology (Section 3.4.1) with respect to withdrawal of surface
water and groundwater.

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The NRC staff typically evaluates impacts on aquatic habitats, as well as on the individual
species and habitats that meet the definition of “important,” as outlined in RG 4.2 (NRC 2024TN7081). Determining which species and habitats potentially affected by a project meet the
criteria for “important” is not possible until a specific site is identified. While the analysis in
Section 3.6.2 is able to consider the potential impacts on many types of important species
generically, it reserves a consideration of potential impacts on federally listed threatened or
endangered species and species regulated under the Magnuson-Stevens Fishery Conservation
and Management Act (Magnuson-Stevens Act; 16 U.S.C. §§ 1801 et seq.; TN1061) until after
receipt of an application. The generic analyses of environmental consequences presented
below therefore address potential impacts on aquatic habitats, food chains, and groupings of
biota, while reserving consideration of potential impacts on federally listed threatened or
endangered species and species regulated under the Magnuson-Stevens Act for projectspecific documentation for the review of a specific license application.

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A number of available databases contain relevant information about aquatic biota for sites
anywhere in the United States. The FWS and National Marine Fisheries Service (NMFS)
maintain online databases regarding the potential occurrence of threatened, endangered,
proposed, or candidate species and critical habitats designated under the Federal ESA
(16 U.S.C. §§ 1531 et seq.; TN1010); and the NMFS maintains maps depicting the geographic
extent of essential fish habitat regulated under the Magnuson-Stevens Act (16 U.S.C. §§ 1801
et seq.; TN1061). Most States have Natural Heritage Programs with databases that contain
information about the locations of species and habitats that have Federal or State special
designations.

3.6.2

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For a nuclear plant meeting the assumptions in the PPE and SPE, the potential for significant
impacts on aquatic ecological resources would generally be minor. There would be a potential
for runoff and sedimentation to affect aquatic habitats during preconstruction and construction,
but the PPE and SPE assume BMPs would be used to minimize adverse effects. There would
also be a potential for limited impacts on wetlands and other shallow surface waters, although
the potential impacts would be limited by the assumptions in the PPE and SPE. It may be
necessary to build transmission lines, pipelines, or access roads spanning rivers, streams, or
other surface waters; and the assumptions in the PPE and SPE allow for limited occurrence of
such encroachments. For plants operated using water-based cooling, operational impacts on
aquatic resources could also result from entrainment and impingement or thermal discharges.
The evaluation below also considers the potential for impacts on aquatic resources from
releases of radionuclides or nonradiological contamination during operations. The evaluation
also considers the possible impacts on aquatic habitats from operation and maintenance of
transmission lines and other facilities on offsite ROWs.

3.6.2.1

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The NRC staff considered the following environmental issues related to aquatic resources for
the building of a new reactor meeting the PPE and SPE:

Aquatic Ecology Impacts

Environmental Consequences of Construction

• runoff and sedimentation from building areas;
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• dredging and filling aquatic habitats to build intake and discharge structures;

• building transmission lines, pipelines, and access roads across surface water bodies; and

• impacts on important species and habitats.

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The NRC staff addressed as a separate issue any impacts on important species as defined for
NRC environmental reviews (NRC 2024-TN7081).

3.6.2.1.1 Runoff and Sedimentation from Construction Areas

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Even though the PPE and SPE assume no more than 0.5 ac of disturbance of aquatic habitats
(including wetlands delineated using the Corps of Engineers Wetlands Delineation Manual
[USACE 1987-TN2066] and regional supplements), physical disturbance of surface soils could
cause runoff and sediment to enter nearby streams, rivers, lakes, and other surface water
features. Precipitation can dislodge soil particles from surface soils exposed by clearing,
grubbing, and grading; and those dislodged particles can become suspended in surface runoff
and be carried overland into nearby surface water features. Upon entering surface waters,
sediment can settle onto the bottom substrate and smother benthic (substrate-borne) flora and
fauna. Runoff and sediment can also block sunlight needed by photosynthetic organisms that
form the base of the aquatic food chain, and runoff can carry soil-borne nutrients such as
phosphorus and nitrogen to surface waters where they can cause rapid growth of algae, plants,
or microorganisms in a process termed eutrophication. These “blooms” of aquatic organisms
can rapidly deplete oxygen carried in the water (dissolved oxygen) needed by fish and other
aquatic organisms, causing suffocation. Runoff and sediment can also carry pesticides and
other chemical contaminants from terrestrial to aquatic settings. The entry of large volumes of
runoff can increase currents and scour bottom sediments, dislodging benthic biota and
increasing sedimentation of downstream habitats. As soil is compacted by building equipment
and structures are built, soil permeability is reduced, and precipitation is prevented from slowly
entering the soil column and is instead directed overland toward aquatic habitats. Rapid flushes
of stormwater following intense precipitation can generate flood flows capable of carrying large
volumes of nutrients or contaminants into aquatic habitats and scouring benthic biota (biota
attached to underwater surfaces).

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Significant erosion and sedimentation of aquatic habitats caused by construction could be
effectively prevented by implementing BMPs. Common BMPs for sedimentation and erosion
control include, but are not limited to, placing silt fences at the perimeter of areas prior to soil
disturbance, installing sediment traps to catch sediment, and temporarily and permanently
stabilizing exposed soil using straw or fast-growing vegetation. Stormwater runoff from
impervious surfaces could be managed by building basins to detain runoff so that more
ultimately moves into the soil column rather than overland to surface waters. Many States or
localities require developers to implement detailed plans for soil erosion and sediment control
and stormwater management.

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Because of the widespread availability of effective BMPs, the staff has determined that runoff
and sedimentation from building areas is a Category 1 issue. The staff concludes that as long
as the applicable PPE and SPE assumptions regarding the permanent and temporary areas of
disturbance are met, the impacts from building a new reactor can be generically determined to
be SMALL. The staff relied on the following PPE and SPE values and assumptions to reach this
conclusion:

• BMPs would be used for erosion and sediment control.

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• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation
once the lands are no longer needed to support building activities.

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Applicants relying on the generic determination would prepare and implement a soil erosion and
sediment control plan and a stormwater management plan that have been approved by all
applicable State and local authorities. If a project involves building in an area where there are no
requirements for regulatory approval of those plans, the PPE and SPE still assume that for
purposes of relying on the generic conclusions in this GEIS, applicants would develop and
implement BMPs commonly recognized as being effective.

3.6.2.1.2 Dredging and Filling Aquatic Habitats to Build Intake and Discharge Structures

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Based on recent license applications for new reactors, building intake and discharge structures
for cooling typically require disturbing no more than 200 linear feet of shoreline and affect less
than 1–2 ac of aquatic habitat per structure. The Tennessee Valley Authority recently estimated
that it would have to build an intake structure measuring approximately 50 ft by 50 ft and a
discharge structure containing two 3 ft pipes to support mechanical draft cooling towers for a
future SMR project in Tennessee (NRC 2019-TN6136). Building those structures would likely
disturb less than 200 ft of shoreline on the reservoir and less than 1 ac of bottom sediment in
the reservoir. An application for a new reactor in Pennsylvania proposed disturbing
approximately 0.61 ac within a river to build an intake structure and approximately 0.46 ac in the
river to build a discharge structure (NRC and USACE 2016-TN6562). Positioning excavation
and building equipment may also require temporarily disturbing a small area of adjoining
riparian habitat, likely under 0.5 ac per structure. The structures are typically built in the same
river, lake, or other source water body but usually have to be established at separate locations
so discharges do not interfere with intakes. The staff has typically concluded that the impacts of
building the intakes and discharges would be minimal as long as the structures qualify for a
NWP 7 under the CWA Section 404 (33 CFR Part 330-TN4318), BMPs are followed, and any
mitigation measures required by the USACE under CWA permits are implemented.

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The PPE does not assume any limitations on the extent of land, shoreline, and riparian
disturbance because of the ability to perform mitigation. Excavation to build the intake and
discharge structures would disturb a small area of aquatic habitat as well as a small area of
adjoining riparian vegetation, thereby influencing the quality of aquatic habitat. The resulting
habitat losses or disturbance would not substantially alter the overall aquatic ecosystem in most
surface water features large enough to function as sources of makeup water. Excavation would
briefly generate plumes of sediment capable of being carried by currents to distant aquatic
habitats; however, it is usually possible to construct small temporary cofferdams around
excavation locations to limit the escape of sediment. Cofferdams temporarily surround the
excavation area with a physical structure that blocks movement of suspended sediment into
adjoining waters. Most surface water bodies large enough to serve as makeup water sources
are navigable or situated on tributary systems and would therefore be regulated as waters of the
United States under the CWA (33 U.S.C. §§ 1251 et seq.; codified as the Federal Water
Pollution Control Act of 1972-TN662). Work to build intake and discharge structures would
therefore require a permit from the USACE under CWA Section 404 but would be covered in
most instances by one or more NWPs (33 CFR Part 330-TN4318).

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The staff has determined that this is a Category 1 issue. The staff concludes that as long as the
assumptions in the PPE and SPE regarding the intake structure are met, the impacts from this
issue can be generically determined to be SMALL. The staff relied on the following PPE and
SPE values and assumptions to reach this conclusion:

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• Applicant would obtain approval, if required, under NWP 7 in 33 CFR Part 330.

• Applicant would implement any mitigation required under NWP 7 in 33 CFR Part 330.

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• Applicant would minimize any temporarily disturbed shoreline and riparian lands needed to
build the intake and discharge structures and restore those areas with regionally indigenous
vegetation suited to those landscape settings once the disturbances are no longer needed.

• BMPs would be used for erosion and sediment control.

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3.6.2.1.3 Building Transmission Lines, Pipelines, and Access Roads across Surface Water
Bodies

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Transmission conductors of any voltage can be built to span rivers, streams, and narrow lakes
without physically disturbing shorelines, sediments, or other components of the channel or
basin. The conductors would not cast a substantial shadow capable of reducing sunlight
reaching the water surface or otherwise altering the condition of the aquatic habitat. The PPE
and SPE assume that conductors would be mounted on towers situated only in uplands and that
no new towers would be built within surface water bodies or adjacent wetlands or floodplains.
Pipelines can typically be built under waterways using directional horizontal drilling, thereby
avoiding physical disturbance of overlying surface water bodies. The PPE and SPE assume that
pipelines would be extended under (or over) surface water bodies through directional drilling (or
aboveground placement) without physically disturbing shorelines or bottom substrate.

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Access roads can be built across smaller streams using a bridge or ford. It is usually possible to
place matting over shallow water areas to facilitate fording with minimal physical disturbance of
shorelines and bottom substrate. Building the bridge abutments or a ford would temporarily
disturb small areas of shoreline and bottom substrate and use of a ford could disturb substrate
each time a vehicle passes. Fish and other mobile aquatic biota may briefly disperse from areas
near a crossing each time the crossing is used due to noise and vibrations caused by the
vehicles. A bridge could also limit the occurrence of aquatic plants and other photosynthetic
organisms because of shading. The assumptions in the PPE and SPE regarding the length of
offsite ROW and the 0.5 ac limit on impacts on wetlands and surface waters function to limit the
number of possible crossings by access roads. Another assumption is that no access roads
would be extended across stream channels over 10 ft in width (at ordinary high water). Crossing
wider streams would likely require building fords or bridges that involve a potential for aquatic
resource impacts and would require project-specific analysis to assess their significance. The
PPE and SPE also assume that no more than 0.5 ac of surface waters or wetlands would be
disturbed. Limiting crossings to streams of that width would limit the potential for habitat
disturbance, disturbance of mobile biota, or generation of sediment.

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No impacts on aquatic resources would likely result from spanning or horizontal drilling under a
surface water body. Extending roadways across waters of the United States typically qualifies
under one or more NWPs (33 CFR Part 330-TN4318), the availability of which supports the
staff’s conclusions. The USACE issues NWPs only for classes of activity determined to
generally not result in significant adverse impacts on aquatic resources and are subject to public
review every 5 years. NWP 12 (temporarily vacated at the present time) applies to utility lines
such as pipelines or transmission lines and NWP 14 applies to linear transportation projects
associated with any project. Both NWPs limit the total disturbance to waters of the United States
and adjacent wetlands to 0.5 ac; additional limitations apply to tidal areas. Applicants relying on
the generic determination would be expected to demonstrate that the USACE has approved
any impacts on waters of the United States under one or more NWPs or that the

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crossings meet the criteria for approval. Applicants would also be expected to implement
BMPs as mitigation to minimize runoff and sedimentation to surface water features from
building transmission lines, access roads, or pipelines.

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Like other CWA permitting requirements, the need for approval under a NWP applies only to
wetlands under CWA jurisdiction. Building transmission lines, pipelines, and access roads could
impact both jurisdictional and non-jurisdictional wetlands or surface water features. The PPE
and SPE therefore includes an assumption that access roads crossing non-jurisdictional surface
water features meet the substantive requirements of NWPs 12 or 14 regarding limits on
disturbance and requirements for mitigation. Both permits limit the cumulative disturbance from
a “single and complete project” to no more than 0.5 ac of jurisdictional surface water features
that can serve as an equivalent benchmark for non-jurisdictional surface water features as well.
While greater impacts on non-jurisdictional surface waters might not be significant, the staff can
only make that determination after review of project-specific information.

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The staff has determined that this is a Category 1 issue. The staff concludes that as long as the
PPE and SPE assumptions established for offsite ROWs are met, the impacts from this issue
can be generically determined to be SMALL. The staff relied on the following PPE and SPE
values and assumptions to reach this conclusion:

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• If activities regulated under the Clean Water Act are performed, they would receive approval
under one or more NWPs (33 CFR Part 330-TN4318) or other general permits recognized
by the USACE.

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• Pipelines would be extended under (or over) surface through directional drilling without
physically disturbing shorelines or bottom substrate.

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• Access roads would span streams and other surface waterbodies with a bridge or ford, and
any fords would include placement and maintenance of matting to minimize physical
disturbance of shorelines and bottom substrates.

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• No access roads would be extended across stream channels over 10 ft in width (at ordinary
high water).

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• Any bridges or fords would be removed once no longer needed, and any exposed soils or
substrate would be revegetated using regionally indigenous vegetation appropriate to the
landscape setting.

• Any mitigation measures indicated in the NWPs or other permits would be implemented.

• BMPs would be used for erosion and sediment control.

3.6.2.1.4 Important Species and Habitats

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Important species and habitats meeting the NRC criteria (NRC 2024-TN7081) for a given site
can only be determined once the site is identified. Because of differing regulations and
sensitivities to impacts, two separate issues are analyzed below regarding important species
and habitats: (1) resources regulated under the ESA (16 U.S.C. §§ 1531 et seq.; TN1010) and
the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act;
16 U.S.C. §§ 1801 et seq.; TN1061), and (2) other important species and habitats.

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Resources Regulated under the Endangered Species Act and Magnuson-Stevens Act

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The FWS has developed online databases and mapping tools that identify threatened,
endangered, proposed, and candidate species under the ESA (16 U.S.C. §§ 1531 et seq.;
TN1010), as well as critical habitats designated under the Act. The NMFS maintains similar
information for marine or anadromous species protected under the Act. NMFS also maintains
maps and other information about essential fish habitats regulated under the MagnusonStevens Act.

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Because these federally regulated resources occur in the same setting and are subject to the
same types of impacts as those considered in Sections 3.5.2.1.1 through 3.5.2.1.5, the
limitations placed upon the extent and intensity of ecological impacts by meeting the
assumptions in the PPE and SPE would likewise limit the potential for impacts on these
resources. However, the staff would need to consult individually with the FWS and/or NMFS
(depending on the specific setting) under the ESA and Magnuson-Stevens Act regarding the
potential impacts from each specific licensing action. Furthermore, with respect to the ESA, the
criteria for listing species are based upon the potential for the most severe of potential
ecological impacts: extinction of species, subspecies, or distinct population segments. Species
that have experienced previous impacts so severe that they are now, or could imminently
become, in danger of extinction may also be substantially more sensitive to impacts that might
only pose minimal threat to other species.

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The staff has therefore determined that building impacts on resources regulated under the ESA
and Magnuson-Stevens Act are a Category 2 issue. Because of their potential for future
regulation over the course of a licensing action, the Category 2 designation extends also to
proposed and candidate species designated under the ESA. Even if the assumptions in the PPE
and SPE discussed in Sections 3.6.2.1.1 through 3.6.2.1.3 are met, the NRC staff is unable to
determine the significance of potential impacts without consideration of project-specific factors,
including the specific species and habitats affected and the types of ecological changes
potentially resulting from each specific licensing action. Furthermore, the ESA and
Magnuson-Stevens Act require consultations for each licensing action that may affect regulated
resources.

Other Important Species and Habitats

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Most States maintain natural heritage databases that identify known occurrences of species and
habitats receiving various categories of State regulation or recognition. Many species and
habitats that do not display the potential for extinction necessary for regulation under the ESA
are still recognized by States because of declining numbers within state boundaries. However,
extirpation from a State is not as severe an impact as complete extinction. Regarding other
types of important species and habitats, most sites containing aquatic habitats may support
commercially or recreationally valuable fisheries, as well as nuisance or invasive species such
as zebra mussels (Dreissena polymorpha), Asiatic clams (Corbicula fluminea), northern
snakehead fish (Channa argus), and invasive aquatic vegetation such as common water
hyacinth (Pontederia crassipes) and Eurasian watermilfoil (Myriophyllum spicatum). Invasive
aquatic species not only adversely affect native aquatic species but can also interfere with
navigation and recreational use of waterways. The NRC staff expects that applicants will
communicate with State and local agencies, private conservation organizations, and other
stakeholders as necessary to determine what other important species and habitats are
potentially present on a site, such as species that have a Federal or State monitoring
requirement or other species of known interest, protected habitats, habitats identified by Federal

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or State agencies as being of high priority for protection, or other habitats of interest such as
nesting or nursery grounds.
The analyses presented above regarding impacts on aquatic resources from specific ecological
issues suggest that the potential impacts on many important species and habitats (NRC 2024TN7081) from building of a new reactor that meets the PPE and SPE would likely be minimal
regardless of site location. The NRC staff is confident in this conclusion for any site meeting the
assumptions in the PPE and SPE discussed in Sections 3.6.2.1.1 through 3.6.2.1.3, even
without identifying the important species specifically present on a given site. The assumptions in
the PPE and SPE limit the potential for adverse impacts, especially limitations on the size of the
footprint of disturbance and the assumed absence of sensitive habitat types potentially
containing rare species. The staff has therefore determined that building impacts on important
species and habitats other than those regulated under the ESA and Magnuson-Stevens Act are
a Category 1 issue. The staff concludes that as long as the assumptions in the PPE and SPE
discussed in Sections 3.6.2.1.1 through 3.6.2.1.3 are met, the impacts can be generically
determined to be SMALL. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:
• Applicants would communicate with State natural resource or conservation agencies
regarding aquatic fish, wildlife, and plants and implement mitigation recommendation of
those agencies.

3.6.2.2

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The NRC staff considered the following environmental issues related to aquatic resources for
building of a new reactor meeting the PPE and SPE assumptions:

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•
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•
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•
•

Environmental Consequences of Operation

stormwater runoff,
exposure of aquatic organisms to radionuclides,
impacts of refurbishment on aquatic biota,
impacts of maintenance dredging on aquatic biota,
impacts of transmission line ROW management on aquatic resources,
impingement and entrainment of aquatic organisms,
thermal impacts on aquatic biota,
other impacts of cooling-water discharges on aquatic biota,
water use conflicts with aquatic resources, and
impacts on important species and habitats.

The list of issues considered is similar to that presented for operations in the License Renewal
GEIS (NRC 2024-TN10161). However, the PPE assumes there will be no use of once-through
cooling systems, cooling ponds, or building of new reservoirs. The PPE also assumes limits on
the quantities of water taken in and discharged for new reactors with dry or water-cooled cooling
towers. The License Renewal GEIS addresses losses from predation, parasitism, and disease
among organisms exposed to sublethal stresses (NRC 2024-TN10161), but those impacts are
encompassed herein as part of the interrelated issues noted above. Any possible impacts from
cooling-tower drift falling on aquatic habitats are addressed as part of the same issue in
Section 3.5.2.

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3.6.2.2.1 Stormwater Runoff
Stormwater runoff generated by impervious surfaces during building is addressed above in
Section 3.6.2.1.1. The potential for stormwater runoff continues as long as impervious surfaces
remain on the site. Typical impervious surfaces at a reactor site include the tops of buildings
and other structures, roads and parking lots, exterior paved areas, walkways and other exterior
“hardscaping” areas. Unpaved but heavily compacted soils can also function as mostly
impervious surfaces and generate substantial quantities of runoff. Chemicals such as
pesticides, paints, and petroleum products are sometimes stored or handled on impervious
surfaces and contribute chemical contamination to runoff. Runoff from roads and parking lots
can contain oil and grease leaked from vehicles. Exterior areas, including landscaped areas,
can also contribute pesticides to runoff potentially reaching aquatic habitats. The potential for
stormwater runoff reaching aquatic habitats is typically minimized through implementation of
stormwater management plans as explained in Section 3.6.2.1.1. As noted in Section 3.10.2.1,
the PPE assumes that licensees would comply with any additional requirements established
through permits for the storage and use of hazardous materials issued by Federal and State
agencies under the Resource Conservation and Recovery Act (RCRA; 42 U.S.C. §§ 6901
et seq.; TN1281). The staff has determined that stormwater runoff during operations is a
Category 1 issue. The staff relied on the following PPE and SPE values and assumptions to
reach this conclusion:

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• Preparation, approval by applicable regulatory agencies, and implementation of a
stormwater management plan.

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• Obtaining and complying with any required permits for the storage and use of hazardous
materials issued by Federal and State agencies under RCRA.

• BMPs would be used for stormwater management.

3.6.2.2.2 Exposure of Aquatic Organisms to Radionuclides

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The NRC staff recognizes that small amounts of radioactive particulates can be released to the
exterior environment during operation of LWRs and evaluated the potential impacts of those
releases on aquatic ecological receptors in the License Renewal GEIS (NRC 2024-TN10161).
Section 3.8.1.2.2 of this GEIS concludes that the impact of routine radiological releases from
past and current operations on aquatic biota would be SMALL. To support that conclusion,
Table 3-5 (in Section 3.8.1 of this GEIS) presents radiological exposure estimates for fish,
invertebrates, and algae modeled using the NRCDose code, as presented in 15 EISs for
proposed new LWRs published between 2006 and 2019. All estimates were substantially lower
than exposure levels considered protective of terrestrial animal populations by the IAEA.

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Additionally, in the License Renewal GEIS (NRC 2024-TN10161), the NRC staff used the
RESRAD-BIOTA dose evaluation model developed by DOE (2004-TN6460) to calculate
estimated dose rates to aquatic biota receptors using REMP reports submitted by licensees for
15 operating LWRs in the United States. RESRAD-BIOTA accounts for possible
bioaccumulation of radionuclides in biological organisms and biomagnification, whereby
radionuclides become concentrated at higher levels in organisms occupying higher positions in
the food chain. The total estimated doses for aquatic biota were all less than 0.2 rad/d
(0.002 Gy/d), considerably less than the guideline value of 1 rad/d (0.01 Gy/d) recognized by
DOE as being protective (DOE 2002-TN4551).

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While many new reactors may use fuels containing differing distributions of radionuclides than
the LWRs considered in the analyses presented above, a reactor meeting the PPE and SPE
would not be likely to result in greater releases of radioactivity. The staff has determined that
exposure of aquatic organisms to radionuclides is a Category 1 issue. The staff concludes that
as long as the project meets the assumptions in the PPE and SPE underlying the analysis in
Section3.8, the impacts can be generically determined to be SMALL, and mitigation would not
be warranted. The staff relied on the following PPE and SPE values and assumptions to reach
this conclusion:
• Applicants would demonstrate in their application that any radiological nonhuman biota
doses would be below IAEA (1992-TN712) and NCRP (1991-TN729) guidelines.

3.6.2.2.3 Effects of Refurbishment on Aquatic Biota

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Refurbishment constitutes the replacement, improvement, or addition of new facilities within the
site of a new reactor throughout its operating life. Examples of possible new facilities might
include additional or expanded storage buildings, parking lots, administration buildings, or
independent spent fuel storage installation. Existing facilities might be demolished or rebuilt in
part. The SPE assumes that there are no surface water features on a site prior to the building of
a new reactor, although it is possible that developers of a new facility might build artificial ponds
or ditches as part of the stormwater management system for the site. These would be the only
possible locations for aquatic habitats on a site that meets the SPE. Any aquatic habitats that
form in these artificial features over time would be simpler and of lower ecological value than
most natural aquatic habitats and because they were generated after development of the site,
they would be easily replaceable. Loss or degradation of these artificial habitats to
accommodate refurbishment would not constitute a noticeable loss of aquatic habitat function in
the landscape. It is possible that over the operational lifetime of a new reactor that work in or
near natural aquatic habitats may be necessary to maintain or replace intake or discharge
structures or pipelines. The impacts would be bounded by the analyses presented above for the
building of those facilities.

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The staff has determined that the impacts of refurbishment on aquatic organisms at an
operating reactor are a Category 1 issue. Impacts can be generically determined to be SMALL
as long as assumptions in the PPE regarding the area of disturbance and the SPE regarding
features within the area of disturbance are met. The staff relied on the following PPE and SPE
values and assumptions to reach this conclusion:

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• BMPs would be used for erosion, sediment control, and stormwater management.
• Exposed soils would be restored as soon as possible with regionally indigenous vegetation.

3.6.2.2.4 Effects of Maintenance Dredging on Aquatic Biota

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The NRC staff recognizes that maintenance dredging of sediment is sometimes necessary
during the operational life of a nuclear power plant, for purposes such as keeping intake screens
free of sediment or removing sediment from areas where boats are used (NRC 2024-TN10161).
As explained in the License Renewal GEIS, accumulation of sediment in standing or slowmoving waters over time is a natural and unavoidable process that requires attention in order to
maintain facilities or navigational capabilities. The License Renewal GEIS describes the
potential impacts on aquatic biota from maintenance dredging at a LWR and concludes that the
impacts would be minimal because of its infrequency and the small areas affected. The extent
of the effects is not likely to be increased by the fuels or technologies of future new reactors.
Dredging of any type is considered under the CWA to constitute “discharge of dredged or fill
material” requiring a permit from the USACE under Section 404 (33 U.S.C. § 1344-TN1019);

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however, dredging for the purpose of maintaining existing navigation capabilities such as marina
basins or boat slips is covered under NWP 35. There are no area or volume limitations
established for NWP 35, although certain conditions regarding the presence of sensitive
resources such as threatened or endangered species or wild and scenic rivers must be met,
and specific mitigation must be implemented. By issuing this NWP, the USACE acknowledges
that such maintenance dredging has minimal potential for having significant environmental
impacts on aquatic resources.

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The staff has determined that the impacts on aquatic organisms of maintenance dredging of any
type at an operating reactor are a Category 1 issue. Impacts can be generically determined to
be SMALL as long as relevant assumptions in the PPE and the SPE are met. The staff relied on
the following PPE and SPE values and assumptions to reach this conclusion:

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• If activities regulated under the Clean Water Act are performed, those activities would
receive approval under one or more NWPs (33 CFR Part 330-TN4318) or other general
permits recognized by the USACE.

• Any mitigation measures indicated in the NWPs or other permits would be implemented.

• BMPs would be used for erosion and sediment control.

3.6.2.2.5 Impacts of Transmission Line ROW Management on Aquatic Resources

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Once a transmission line is built, the ROW requires routine maintenance to keep it free of trees
tall enough to cause electrical current to arc through vegetation to the ground. It may also be
necessary to remove or trim trees growing near the edge of the ROW capable of falling too
close to the conductors (commonly termed “danger trees”). Some utilities also maintain
“screens” of low trees under transmission line conductors where they cross aesthetically
sensitive suburban roadways; such tree screens require frequent maintenance. Sometimes
relatively level upland areas on transmission line ROWs, especially in aesthetically sensitive
residential areas, are periodically mowed. But the most common techniques in managing
transmission line ROWs involve use of herbicides. Herbicides can be applied directly to
vegetation in the ROW, or to cut stump surfaces once trees are felled. Even when applied in
uplands, herbicides can be carried in overland runoff to streams or other surface water features.
Herbicides can also leach into groundwater under application sites and be carried to surface
waters. Herbicides entering aquatic habitats vary in their lethality to aquatic organisms
depending on their active ingredient but also on how they are formulated. For example,
formulations of the nonselective herbicide glyphosate labeled for use in upland settings are
more lethal to aquatic biota than are glyphosate formulations labeled for use in wetlands or near
aquatic features (Langeland and Gettys 2015-TN6461).

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Operation of spray equipment or mowers on ROWs can physically disturb soils, thereby
generating small amounts of sedimentation that can enter aquatic habitats (see
Section 3.6.2.1.1 for an explanation of the impacts of sedimentation on aquatic biota).
Maintenance of service roads on the ROW can also cause small amounts of sedimentation.
Heavy equipment traversing streams or wetlands can physically damage aquatic biota and the
soils and sediment supporting aquatic biota. The potential for noticeable adverse impacts on
aquatic habitats from sedimentation can be readily prevented using BMPs. Physical disturbance
of soils and sediments in aquatic habitats by fording equipment can be prevented by use of
temporary matting that can be removed once it is longer needed. The NRC staff considered
possible impacts of transmission line ROW maintenance on aquatic habitats associated with
relicensing of existing LWRs and concluded that impacts would be minimal because they would
be infrequent, localized, and temporary (NRC 2024-TN10161).

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The staff has determined that the impacts of transmission line maintenance on aquatic biota are
a Category 1 issue. The staff concludes that as long as the assumptions in the PPE and SPE
regarding work in offsite ROWs are met, the impacts can be generically determined to be
SMALL. The staff relied on the following PPE and SPE values and assumptions to reach this
conclusion:

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• Vegetation in transmission line ROWs would be managed following a plan consisting of
integrated vegetation management practices.

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• All ROW maintenance work would be performed in compliance with all applicable laws and
regulations.

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• Herbicides would be applied by licensed applicators, and only if in compliance with
applicable manufacturer label instructions.

• BMPs would be used for erosion and sediment control.

3.6.2.2.6 Impingement and Entrainment of Aquatic Organisms

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Impingement and entrainment of aquatic organisms is a consideration only for facilities whose
operation involves use of intake structures for cooling water. The PPE assumes recirculating
cooling-water systems using cooling towers but not using once-through cooling systems that
require intake of substantially larger volumes of water. The potential for impingement or
entrainment generally increases with the volume of water withdrawn and the velocity of
movement through the intake screen. For purposes of regulation under CWA Section 316(b),
the EPA defines impingement as the entrapment of all life stages of fish and shellfish on the
outer part of an intake structure or against a screening device during periods of water
withdrawal (40 CFR 125.83; TN254). The EPA defines entrainment as incorporation of all life
stages of fish and shellfish with intake water flow entering and passing through a cooling-water
intake structure and into a cooling-water system (40 CFR 125.83). Impingement can immobilize
organisms rendering them subject to starvation or predation. Organisms that are entrained may
pass through the cooling system and emerge in the discharge but are usually killed or
substantially injured in the process. Although the EPA regulatory definitions address only fish
and shellfish, plankton, comprising both faunal (zooplankton) and floral (phytoplankton)
organisms carried by water currents, may also be entrained. Impacts on plankton can harm fish
and shellfish by altering supportive food chains.

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The PPE includes limits on flow rates at intake structures based on regulatory limits established
by EPA in 40 CFR 125.84 (TN254) to protect fish and shellfish. The regulations establish a
maximum through-screen velocity of 0.5 ft/s. The total design intake flow must generally be no
more than 5 percent of the mean annual flow of rivers or streams and low enough to not disturb
natural thermal stratification or turnover in lakes or reservoirs. Thermal stratification is the
formation of layers of water of differing temperatures in standing water bodies due to
temperature-related differences in water density. Turnover is the shifting of layers in the water
column in response to seasonal changes in temperature. Both the stratification and seasonal
turnover can be highly influential on the development and survival of aquatic biota. For
intakes in tidal water bodies, the regulations limit intake to less than 1 percent of the volume
of the water column centered around the opening to the intake structure. The regulations
establish additional requirements, including monitoring requirements, to ensure that
these rates of intake are protective of fish and shellfish.

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The NRC staff included a description of the potential impacts of impingement and entrainment
of aquatic biota from operation of large LWRs in Section 4.6.1.2 of the License Renewal GEIS

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(NRC 2024-TN10161). Even though the staff identified potentially significant impacts from
impingement and entrainment for operating plants with once-through cooling systems (NRC
2024-TN10161), they also noted that substantial reductions of aquatic biota populations did not
occur during operation of plants that have cooling towers because of the smaller volume of
water intake (NRC 2024-TN10161). Cooling towers require less water intake because they
recirculate the same water for multiple cycles of cooling before discharge and replacement.
Cooling systems for nuclear as well as non-nuclear power plants operate independently of the
fuel or power generation technology; hence, the minimal impacts observed with large LWRs
suggest that similarly minimal impacts would result from operation of new reactors using any
fuel or technology.

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The staff has determined that impingement and entrainment of aquatic biota is a Category 1
issue. The staff concludes that as long relevant PPE and SPE are met, the impacts can be
generically determined to be SMALL. The staff relied on the following PPE and SPE values and
assumptions to reach this conclusion:

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• Intakes would comply with regulatory requirements established by EPA in 40 CFR 125.84
(TN254) to be protective of fish and shellfish.

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• Best available control technology would be employed in the design of intakes to minimize
entrainment and impingement, such as use of screens and intake rates recognized to
minimize effects.

3.6.2.2.7 Thermal Impacts on Aquatic Biota

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Operation of power plants requires the disposition of excess heat generated by the fuel but not
converted into electricity. Although some new reactors may be air-cooled, whereby the waste
heat is transferred to air, others, like most large LWRs, may be water-cooled, whereby the
waste heat is transferred to water. The PPE assumes no use of once-through cooling systems,
whereby makeup water is withdrawn and passed over-heat exchangers only once before being
discharged. New reactors within the PPE may however use recirculated-water cooling systems
where makeup water is passed over the heat exchangers and run through a cooling tower to
dissipate most of its heat content to the air before being recirculated to dissipate more heat in
the same way. After recirculation for a specified number of passes (cycles of concentration), the
cooling water is discharged as blowdown to a river, lake, or other surface water body (usually
the same body that provided the makeup water). The thermal quality of discharges is regulated
under CWA Section 316(a), under which the EPA and States can issue thermal variances as
part of NPDES permits.

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If water is discharged at a temperature higher than that of the receiving water, the discharges
can affect aquatic biota. Aquatic biota are adapted to seasonal patterns of water temperatures,
including seasonal turnover of stratified water column layers. A particularly serious problem is
heat shock: fish and other aquatic biota favoring warmer water temperatures congregate in the
vicinity of heated water discharges that persist only as long as a power plant is in operation, but
are faced with suddenly colder water whenever operations cease for maintenance or refueling.
Increased water temperatures can also encourage growth of invasive aquatic species such as
hydrilla (Hydrilla verticillata) and Eurasian watermilfoil (Myriophyllum spicatum).

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The NRC staff included a description of the potential thermal impacts on aquatic biota from
operation of large LWRs in Section 4.6.1.2 of the License Renewal GEIS (NRC 2024-TN10161).
Even though staff identified potentially significant impacts from thermal impacts for operating
nuclear plants with once-through cooling systems (NRC 2024-TN10161), the staff also
concluded that the impacts were minimal from nuclear plants using cooling towers because of

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the smaller discharge plumes resulting from the reduced volume of water being discharged
(NRC 2024-TN10161). Cooling systems operate independently of the fuel or power generation
technology; hence, the minimal impacts observed with large LWRs provide evidence that
similarly minimal impacts would result from operation of new reactors using any fuel or
technology. However, the conclusion in the License Renewal GEIS that impacts would be
minimal was reached after a review of a series of existing reactors under known conditions. As
discussed in Section 3.4.2.2.7, project-specific reviews included an estimation of the extents of
the mixing zones in the receiving water bodies and how the mixing zone may affect aquatic
resources under project-specific conditions.

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The staff concludes that the impact of thermal impacts on aquatic biota is a Category 2 issue.
The staff concludes that it is not possible to generically evaluate the potential impacts of the
thermal impacts on aquatic ecosystems without first considering project-specific factors. The
staff would have to first review the discharge plume analysis (as described in Section 3.4.2.2.7)
and the aquatic biota potentially present before being able to reach a conclusion regarding the
possible significance of impacts on that biota.

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However, this issue is relevant only to nuclear power plants that will have discharges (other than
stormwater discharges) to surface water during operations. In general, nuclear power plants that
do not use water for cooling do not have discharges capable of adversely affecting aquatic
biota. For such plants, detailed analysis of thermal impacts on aquatic biota are not necessary.

3.6.2.2.8 Other Effects of Cooling-Water Discharges on Aquatic Biota

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The NRC staff recognizes that discharges of cooling-tower blowdown water from operating
nuclear power plants can release nonradiological contaminants to aquatic habitats (NRC 2024TN10161). The License Renewal GEIS discusses copper introduced into cooling water when it
passes over copper alloy tubes used in a few existing LWRs but notes that those tubes have
been replaced by tubes made of other metals such as titanium as mitigation. The PPE therefore
assumes that copper alloy tubes would not be used in new reactors. Operators of nuclear power
plants that use cooling towers typically add biocides to the cooling water to prevent the buildup
of microorganisms, algae, and invasive species such as zebra mussels and Asiatic clams that
can interfere with water conveyance. As explained in the License Renewal GEIS (NRC 2024TN10161), NPDES permits include restrictions on biocide use to protect non-target organisms in
receiving waters such as indigenous mussels and fish. Various methods are available to
minimize biocide use in order to comply with NPDES permits. Cooling water can also affect
dissolved oxygen levels and cause eutrophication in receiving waters, and discharges can
cause localized areas of gas supersaturation (gas bubbles) that are detrimental to aquatic biota,
but the staff has concluded in the License Renewal GEIS that the impacts would be minor (NRC
2024-TN10161). However, development of a bounding set of plant parameters for the PPE or
site parameters for the SPE that are adequately protective of aquatic biota is not possible,
because compliance with standards set forth in an NPDES permit would not necessarily result
in only minimal impacts on aquatic biota in all settings. This is especially true for discharges to
waters not under the CWA jurisdiction and hence not requiring an NPDES permit.

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The staff therefore concludes that the impact of cooling-water discharges on aquatic biota is a
Category 2 issue. The staff concludes that it is not possible to generically evaluate the potential
impacts of the discharges on aquatic ecosystems without first considering project-specific
factors. The staff would have to first review the discharge plume analysis (as described in
Section 3.4.2.2.7) and the aquatic biota potentially present before being able to reach a
conclusion regarding the possible significance of impacts on that biota.

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However, this issue is relevant only to nuclear power plants that will have discharges (other than
stormwater discharges) to surface water during operations. In general, nuclear power plants that
do not use water for cooling do not have discharges capable of adversely affecting aquatic
biota. For such nuclear power plants, detailed analysis of cooling water discharges on aquatic
biota is not necessary.

3.6.2.2.9 Water Use Conflicts with Aquatic Resources

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The water demands for operating a nuclear reactor are typically low unless water is used for
cooling purposes. The more substantive demands for cooling water could however reduce water
levels in some aquatic habitats. Recirculating cooling-water systems withdraw water and
repeatedly cycle it through multiple passes over the heat exchangers, evaporating a portion of
the water in each cycle. Substantially less water is therefore discharged back to the source
water body than is withdrawn. The reduced water availability can reduce flow in streams and
rivers, reduce water elevations in lakes and reservoirs, contract shorelines, and periodically dry
out shallow areas and wetlands. As discussed in Section 3.5.2.2.7, the assumption in the SPE
regarding water use and surface water availability applies to flowing systems. Water
withdrawals from streams or rivers would constitute less than 3 percent of the 95 percent
exceedance daily flow (essentially, extreme low flow conditions), which would ensure that
aquatic fauna and flora in riverine habitats would not experience adverse effects caused by
hydrological changes during droughts.

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The staff recognizes that it is not as easy to estimate the potential impacts of water withdrawals
on non-flowing surface water bodies. The PPE value of 6,000 gpm (Section 3.4.1) for total plant
water demand applies to non-flowing water bodies such as the Great Lakes, the Gulf of Mexico,
oceans, estuaries, and intertidal zones. The staff recognizes that the quantity of water
withdrawals for new reactors from very large water bodies such as oceans, the Great Lakes,
and the Gulf of Mexico would not result in a reduction in water levels or hydroperiod that could
adversely affect the ecological integrity of aquatic habitats or biota. However, water withdrawals
from smaller or more sensitive non-flowing fresh water bodies such as inland lakes and
reservoirs, estuaries, and intertidal zones could require project-specific review of the potential
impacts of changes in water level and hydroperiod (Section 3.5.2.2.7). The staff assumes that
applicants relying on the generic analysis can demonstrate that hydroperiod changes are within
historical annual or seasonal fluctuations. If the applicant cannot so demonstrate, projectspecific analysis would be needed to determine potential impacts on aquatic habitats.

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The water losses resulting from operation of cooling-water systems for power plants are unlikely
to result in substantial changes to most aquatic ecosystems under normal conditions but could
be noticeable during times of extended drought. In the License Renewal GEIS, the NRC staff
determined that evaluating the potential impacts of water use conflicts with aquatic biota
requires a project-specific analysis for the individual reactor undergoing relicensing (NRC 2024TN10161). However, for this GEIS (unlike in the License Renewal GEIS), the staff relies on
assumptions in the PPE and SPE regarding water use that the staff developed to limit potential
adverse effects on aquatic habitats. The staff has therefore determined that water use conflicts
with aquatic biota are a Category 1 issue. The staff concludes that as long as relevant values
and assumptions in the PPE and SPE regarding cooling systems (Section 3.6.1) and
assumptions regarding surface water withdrawal (Section 3.4.1) are met, including that it is
possible to demonstrate that hydroperiod changes are within historical or seasonal fluctuations,
the impacts can be generically determined to be SMALL. The staff relied on the following PPE
and SPE values and assumptions to reach this conclusion:

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• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in
height; and equipped with drift eliminators.

• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).

• Total plant water demand would be less than or equal to a daily average of 6,000 gpm.

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• If water is withdrawn from flowing waterbodies, average plant water withdrawals would not
reduce flow by more than 3 percent of the 95 percent exceedance daily flow and would not
prevent maintenance of applicable instream flow requirements.

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• Any water withdrawals would be in compliance with any EPA or State permitting
requirements.

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• Applicants would be able to demonstrate that hydroperiod changes are within historical or
seasonal fluctuations.

3.6.2.2.10 Important Species and Habitats

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As noted for building, important species and habitats that meet the NRC criteria (NRC 2024TN7081) on a given site can only be determined once the site is identified. Because of differing
regulations and sensitivities to impacts, two separate issues are analyzed below regarding
important species and habitats: (1) resources regulated under the ESA (16 U.S.C.
§§ 1531 et seq.; TN1010) and the Magnuson-Stevens Act (16 U.S.C. §§ 1801 et seq.; TN1061),
and (2) other important species and habitats.

Resources Regulated under the Endangered Species Act and Magnuson-Stevens Act

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For the same reasons noted for building in Section 3.6.2.1.4, the staff has determined that
operational impacts on resources regulated under the ESA and Magnuson-Stevens Act are a
Category 2 issue. Because of their potential for future regulation over the course of a licensing
action, the Category 2 designation extends also to proposed and candidate species designated
under the ESA. Even if the applicable assumptions in the PPE and SPE are met, the NRC staff
is unable to determine the significance of potential impacts without consideration of projectspecific factors, including the specific species and habitats affected and the types of ecological
changes potentially resulting from each specific licensing action. Furthermore, the ESA and
Magnuson-Stevens Act require consultations for each licensing action that may affect regulated
resources.

Other Important Species and Habitats

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The analyses presented in Section 3.6.2.1.4 also apply to operations and suggest that the
potential impacts on other important species and habitats from operation of a new reactor that
meets the PPE and SPE would likely be minimal regardless of site location. The NRC staff is
confident in this conclusion for any site that meets the assumptions in the PPE and SPE
associated with cooling systems and meets the regulatory limits in 40 CFR 125.84 (TN254) and
requirements associated with applicable NPDES permits, even without identifying the important
species specifically present on a given site. The assumptions in the PPE and SPE limit the
potential for adverse impacts, especially limitations on the amount of water used and the
assumed absence of sensitive habitat types potentially containing rare species. Licensees
would also likely communicate with multiple State and local authorities, who may recommend
following routine BMPs to prevent the introduction of invasive species to affected water bodies.

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The staff has therefore determined that operational impacts on important species and habitats
other than those regulated under the ESA and Magnuson-Stevens Act are a Category 1 issue.
The staff concludes that as long as the applicable assumptions in the PPE and SPE are met,
the impacts can be generically determined to be SMALL. The staff relied on the following PPE
and SPE values and assumptions to reach this conclusion:
• Applicants would communicate with State natural resource or conservation agencies
regarding aquatic fish, wildlife, and plants and implement mitigation recommendation of
those agencies.

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3.7

Historic and Cultural Resources

3.7.1

Baseline Conditions

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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 pre-date 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 (TCPs) important to a living community of people for maintaining its culture. 7

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Within the scope of the National Historic Preservation Act of 1966 (NHPA; 54 U.S.C.
§§ 300101 et seq.; TN4157), a historic or a cultural resource is considered a historic property if
it has met at least one of the four criteria for listing or is listed on the NRHP.8 The NRHP is the
Nation’s official list recognizing buildings, structures, objects, sites, and districts of national,
State, or local places that are historically significant and worthy of preservation. The list is
maintained by the U.S. National Park Service in accordance with its regulations in 36 CFR
Part 60 (TN1682). The NRHP criteria to evaluate the eligibility of a property are set forth in
36 CFR 60.4.9 In this regard, a historic property is at least 50 years old, although exceptions can
be made for properties determined to be of “exceptional significance.”10

According to U.S. National Park Service (NPS) guidance, a “traditional cultural property” is associated “with the
cultural practices or beliefs of a living community that (a) are rooted in that community's history, and (b) are important
in maintaining the continuing cultural identity of the community” (Parker and King 1998-TN5840).
8
Historic property is defined in 36 CFR 800.16(l)(1) (TN513) as “... any prehistoric or historic district, site, building,
structure, or object included in, or eligible for inclusion in, the [NRHP] maintained by the Secretary of Interior. This
term includes artifacts, records, and remains that are related to and located within such properties.” As defined in 36
CFR 800.16(l)(2), “The term eligible for inclusion in the National Register includes both properties formally
determined as such in accordance with regulations of the Secretary of the Interior and all other properties that meet
National Register listing criteria.”
9
The eligibility of a resource for listing on the NRHP is evaluated based on four criteria and is articulated in
36 CFR 60.4 (TN1682), as follows: Criterion a: Associated with events that have made a significant contribution to
broad patterns of our history; Criterion b: Associated with the lives of persons significant in our past; or Criterion c:
Embodies the distinctive characteristics of a type, period, or method of construction, or represents the work of a
master, or that possesses high artistic values, or that represents a significant and distinguishable entity whose
components may lack individual distinction; and Criterion d: Has yielded, or is likely to yield, information important to
prehistory and history.
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36 CFR 60.4(g).
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3.7.1.1

National Historic Preservation Act and NEPA

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NEPA (42 U.S.C. §§ 4321 et seq.; TN661) 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 on the National Register would also need to be
considered (CEQ and ACHP 2013-TN4603).

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Section 106 of the NHPA (54 U.S.C. §§ 300101 et seq.; TN4157) requires Federal agencies to
take into account the effects of their undertakings11 on historic properties and consult with the
appropriate consulting parties as defined in 36 CFR 800.2 (TN513). Consulting parties consist
of the State Historic Preservation Officer (SHPO), Advisory Council on Historic Preservation
(ACHP), Tribal Historic Preservation Officer (THPO), 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. The ACHP is an independent Federal agency that
oversees the NHPA Section 106 review process in accordance with its implementing regulations
in 36 CFR Part 800, Protection of Historic Properties (TN513). Issuing a license for a new
reactor is an undertaking that requires compliance with NHPA Section 106.

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Historic and cultural resources vary widely from site to site; there is no generic way of
determining their existence or significance. Historic and cultural resource impacts must be
analyzed on a project-specific basis, and the NRC is required to complete a NEPA and NHPA
Section 106 review (NRC 2024-TN7081) prior to issuing a license.12

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For a specific application, in accordance with 36 CFR Part 800 (TN513), the NRC would
establish the undertaking, identify consulting parties, and determine the scope of potential
effects from the undertaking by defining the area of potential effect (APE). The APE for a new
reactor is the area that may be directly (e.g., physical) or indirectly (e.g., visual and auditory)
affected by activities during construction or plant operations. The APE typically encompasses
the nuclear power plant site where onsite ground-disturbing activities may occur, its immediate
environs including viewshed, and in-scope transmission lines. The APE may extend beyond the
nuclear plant site and transmission lines when building and operation activities may affect
historic properties at offsite locations. The NRC will rely on cultural resource investigations of
the APE and NRHP-eligibility evaluations completed by qualified professionals, who meet the
Secretary of Interior’s standards at 36 CFR Part 61 (TN4848), in consultation with the SHPO
and other consulting parties to determine whether historic properties are present in the APE.

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When preparing project-specific supplements to this GEIS (see 36 CFR 800.8(c); TN513), the
NRC’s practice is to fulfill the requirements of NHPA Section 106 through the NEPA review
process. Additional historic and cultural resource laws could apply if a proposed project is
located on Federal lands (see Appendix F).

An undertaking is defined as “a project, activity, or program funded in whole or in part under the direct or indirect
jurisdiction of a Federal agency, including those carried out by or on behalf of a Federal agency; those carried out
with Federal financial assistance; and those requiring a Federal permit, license, or approval” (see CFR 800.16(y);
TN513).
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The NRC is required to comply with the NHPA including the anticipatory demolition clause, Section 110(k) of the
NHPA (54 U.S.C. 306113). See Section 4.6 of RG 4.2 (NRC 2022-TN7081)

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3.7.2

Historic and Cultural Resources Impacts

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The NRC considers impacts on historic and cultural resources in this GEIS through its NEPA
requirements in 10 CFR Part 51 (TN250). Impacts may be direct, indirect, visual, or auditory.
Any new construction activity, including the building and operation of a new reactor, parking
areas, access roads, or transmission lines, is particularly important to an analysis of impacts on
historic and cultural resources. Building- and operation-related ground-disturbing activities or
alterations to buildings or structures that are NRHP-eligible can result in direct effects on
archaeological sites, aboveground resources, and TCPs. Introduction of noise or visual
intrusions (i.e., use of reflective materials, tall structures, building design that is inconsistent with
surrounding environment) that are either temporary or permanent in nature can result in both
direct and indirect effects on aboveground resources and TCPs.

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The NRC staff will rely on preliminary recommendations made by qualified professionals, who
meet the Secretary of Interior’s standards at 36 CFR Part 61 (TN4848), in its determination of
whether historic properties will be or will not be adversely affected. For a historic or cultural
resource that does not meet the criteria to be considered a historic property under the NHPA,
the NRC will assess whether there are any potential significant impacts on this resource through
the NEPA process.

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If historic and cultural resource investigations do not identify historic properties within the APE,
the NRC will conclude a finding of no historic properties affected in accordance with 36 CFR
800.4(d)(1) (TN513). The NRC will provide documentation of these findings for review and
concurrence to SHPO/THPO, American Indian Tribes, and interested members of the public in
accordance with documentation standards set forth in 36 CFR 800.11(d).

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If historic properties have been identified but would not be impacted by the proposed
construction and operation activities, or if the impacts can be either minimized or avoided, the
NRC staff will apply the criteria of no adverse effect on historic properties outlined in 36 CFR
800.5(b). The NRC will provide documentation of these findings for review and concurrence to
SHPO/THPO, American Indian Tribes, and interested members of the public in accordance with
documentation standards set forth in 36 CFR 800.11(e).

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If historic properties have been identified and cannot be avoided by the proposed construction
and operation activities, the NRC staff will apply the criteria of adverse effect to historic
properties outlined in 36 CFR 800.5(a) (TN513). Adverse effects result when an undertaking
may alter, directly or indirectly, any of the characteristics of a historic property that qualify the
property for inclusion on the NRHP in a manner that would diminish the integrity of the
property’s location, design, setting, materials, workmanship, feeling, or association. These
include physical destruction or alteration of a property’s characteristics that contribute to its
historic significance. Examples of adverse effects are described in 36 CFR 800.5(a)(2).

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The NRC staff will provide documentation of this finding to the ACHP, SHPO/THPO, Indian
Tribes, and interested members of the public for review and concurrence in accordance with
documentation standards set forth in 36 CFR 800.11(e) (TN513). The NRC will consult with the
same parties regarding the resolution of adverse effects and develop measures to avoid,
minimize, or mitigate the adverse effects. Such measures to address adverse effects are
typically documented in a Memorandum of Agreement or a Programmatic Agreement.

3.7.2.1

The NRC staff identified one environmental issue:

Environmental Consequences of Construction

• construction impacts on historic and cultural resources

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Most impacts on historic and cultural resources would occur during the construction phase.
Impacts would occur primarily from both onsite and offsite preparation-related ground-disturbing
activities (e.g., land clearing, grading and excavation, and road work) and the construction of
safety-related facilities such as the nuclear island and non-safety-related facilities such as
cooling towers, administration buildings, parking lots, switchyards, pipelines, access roads, and
transmission lines. Archaeological sites are sensitive to disturbance and even a small amount of
ground disturbance (e.g., ground clearing and grading) could affect a significant resource. Much
of the information contained in an archaeological site is derived from the spatial relationships
between soil layers and associated artifacts. Once these spatial relationships are altered, they
can never be reclaimed (NRC 2024-TN10161). Alterations to the visual setting, whether
temporary or permanent, could also affect other types of historic and cultural resources such as
cultural landscapes, architectural resources, or TCPs.

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Direct and indirect impacts from construction on historic and cultural resources and historic
properties can be avoided or minimized if the undertaking is modified or if the applicant takes
the appropriate mitigation measures. Impacts on archaeological resources can typically be
avoided by re-siting ground-disturbing activities. Minimization efforts can include but are not
limited to use of geomembranes or geotextile fabric to protect and/or stabilize archaeological
deposits, construction monitoring, and development of inadvertent discovery plans. Direct
impacts on aboveground resources can be avoided by not altering any of the exterior or interior
physical components of the building that contribute to its NRHP eligibility. Indirect impacts can
be avoided by existing natural topography or vegetation screening. Minimization efforts for
aboveground resources can include but are not limited to vegetation restoration, creative
landscaping, integration of structures with the surrounding environment, minimization of the use
of bright flashy surfaces, and other considerations related to overall design. Adaptive reuse of
an aboveground resource is often viewed as a beneficial effect depending on the scope of
modifications necessary.

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If impacts on a historic property cannot be avoided or minimized, they can be mitigated through
the development of mitigation measures that are formalized in an Memorandum of Agreement
or a Programmatic Agreement. Historic and cultural resources are nonrenewable, hence certain
activities depending upon the resource and its significance can result in an irretrievable loss of
the resource. Mitigation efforts for archaeological sites typically entail data recovery and
controlled excavation if in situ stabilization is not possible. Despite being a form of mitigation,
archaeological data recovery results in an irretrievable loss of the historic and archaeological
information. Mitigation efforts for aboveground resources can include but are not limited to
formal documentation in a Historic American Buildings Survey/Historic American Engineering
Record (HABS/HAER) study and public education activities. Development of avoidance,
minimization, and mitigation measures for adverse effects on TCPs must be done in
consultation with the tribe or community that has an interest in that TCP.

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This GEIS does not identify any specific sites for NRC licensing actions that would trigger NHPA
Section 106 consultation requirements that are normally conducted during project-specific
licensing reviews. Development of this GEIS is not a licensing action; it does not authorize the
building or operation of any new reactor. Because the analysis requires project-specific
information, the impact of building a new reactor on historic and cultural resources is a
Category 2 issue.

3.7.2.2

The NRC staff identified one environmental issue:

Environmental Consequences of Operation

• operation impacts on historic and cultural resources
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Continued operations can affect historic and cultural resources through ground-disturbing
activities associated with plant operations and ongoing maintenance of existing onsite and
offsite facilities, roads, and transmission lines; and changes to the appearance of the nuclear
power plant and transmission lines. Impacts from operation and maintenance activities on
historic and cultural resources and historic properties can be avoided or minimized through the
development of historic and cultural resource protection procedures. These procedures outline
stop work and notification protocols in the event that archaeological materials or human remains
are inadvertently discovered during building, operation, or maintenance activities. The
procedures should follow State burial laws if the new reactor is sited on non-Federal land or the
Native American Graves Protection and Repatriation Act (25 U.S.C. §§ 3001 et seq.; TN1686) if
it is sited on Federal land. Development of avoidance, minimization, and mitigation measures
(i.e., stop work and notification procedures) for addressing adverse effects on historic properties
must be done in consultation with SHPO/THPO and Indian Tribes.

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NHPA Section 106 consultation requirements are normally conducted during project-specific
licensing reviews. This GEIS is not a licensing action; it does not authorize the construction or
operation of any new reactor. Because the analysis requires project-specific information, the
impact of operating a new reactor on historic and cultural resources is a Category 2 issue.

3.8

3.8.1

3.8.1.1

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Radiological exposures from nuclear power plants include offsite doses to members of the
public and onsite doses to the workforce. Each of these impacts is common to all commercial
U.S. reactors. The Atomic Energy Act of 1954 (42 U.S.C. §§ 2011 et seq.; TN663) requires the
NRC to promulgate, inspect, and enforce standards that provide an adequate level of
protection for public health and safety and the environment. The NRC continuously evaluates
the latest radiation protection recommendations from international and national scientific
bodies to establish the requirements for nuclear power plant licensees. The NRC has
established multiple layers of radiation protection limits to protect the public from potential
health risks related to exposure to radioactive materials effluent discharges from nuclear
power plant operations. If the licensees exceed a certain fraction of these dose levels in a
calendar quarter, they are required to notify the NRC, investigate the cause, and
initiate corrective actions within the specified time frame.

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An assessment of the radiological environment for a proposed site on which to build and
operate a nuclear power plant would depend on the characteristics of the site relative to prior
and adjacent activities. If the site has not been used for any prior industrial activities, i.e., it is a
greenfield site, then the environment is only affected by natural radioactive background.
However, if the footprint of the proposed nuclear power plant is within an existing licensed
nuclear facility’s property, there is an adjacent or nearby nuclear facility (e.g., nuclear power
plant, nuclear fuel cycle facility, or another NRC-licensed, Agreement State-licensed, or Federal
nuclear facility), or the site was a former nuclear facility, then radiological effects from such
nuclear facilities, such as direct radiation or residual radionuclides in the soil on the proposed
site, should already have been assessed for their impacts with respect to regulatory
requirements (10 CFR 20.1101, CFR 20.1201, 10 CFR 20.1301, 10 CFR Part 20 Appendix B
[10 CFR Part 20-TN283]).

Environmental Hazards
Radiological Environment
Baseline Conditions and PPE/SPE Values and Assumptions

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Existing licensed nuclear facilities have a REMP. The limits for all radiological releases are
specified in a nuclear power plant’s Offsite Dose Calculation Manual, and these limits are
designed to meet Federal standards and requirements. The REMP includes monitoring of the
aquatic environment (fish, invertebrates, and shoreline sediment), atmospheric environment
(airborne radioiodine, gross beta, and gamma), terrestrial environment (vegetation), and direct
radiation. These reports have shown that doses to individuals around the nuclear site were a
small fraction of the limits specified in Federal environmental radiation standards (10 CFR
Part 20 [TN283], 10 CFR Part 50 [TN249], Appendix I, and 40 CFR Part 190 [TN739]).

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In an Atomic Safety Licensing Board initial decision for the North Anna ESPs (ASLB 2007TN6826) it was ruled that the limits in 40 CFR 190.10 (TN739)—and hence 10 CFR 20.1301(e)
(TN283)—do not apply to non-LWRs. EPA’s radiation protection standard applies to operations
within the “uranium fuel cycle,” which it defines as the processes involved in the production of
uranium fuel, “generation of electricity by a light-water cooled nuclear power plant using uranium
fuel,” and reprocessing spent uranium fuel. This definition excludes gas-cooled, molten saltcooled, liquid metal-cooled, and heat pipe-cooled nuclear power reactors, regardless of fuel
composition. Therefore, under the current regulatory scheme, non-LWR nuclear power reactors
would not be subject to the dose limits of 10 CFR 20.1301(e) for the applicable environmental
radiation standards in 40 CFR 190.10. In addition, 10 CFR Part 50 (TN249), Appendix I,
provides “numerical guidance on design objectives for [LWRs] to meet the requirements that
radioactive material in effluents released to unrestricted areas be kept [ALARA].” No similar
specific numerical guidance on design objectives currently exist for non-LWRs. However, the
staff assumes that the ALARA design objective requirements in 10 CFR 50.34a (see below) and
radiation protection programs under 10 CFR 20.1101 (TN283), which are applicable to
non-LWR licensees, will ensure that radioactive effluent releases from non-LWRs should remain
below applicable regulatory limits. The use of 40 CFR Part 190 (TN739) limits and the results in
Table 3-2 to Table 3-6 are provided as examples for demonstrating small impacts.

3.8.1.1.1 Regulatory Requirements and Guidance

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Nuclear power reactors in the United States must be licensed by the NRC and must comply with
NRC regulations and conditions specified in the license in order to operate. The application
must provide assurance that the limits on the release of radioactive liquid and gaseous effluents
during normal operation (including expected operational occurrences) will meet the
requirements in 10 CFR Part 20 (TN283), Subpart B, “Radiation Protection Programs,”
Subpart C, “Occupational Dose Limits for Adults,” and Subpart D, “Radiation Dose Limits for
Individual Members of the Public.” In addition, a new reactor applicant would need to meet the
following 10 CFR Part 20 and 10 CFR Part 50 (TN249) regulations concerning radioactive
effluent releases:

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• applicable 10 CFR Part 20, Appendix B (TN283) regulatory standards for discharge
radioactive effluents;

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• the requirements in 10 CFR 50.34a, “Design objectives for equipment to control releases of
radioactive material in effluents—nuclear power reactors” (TN249); and

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• the special license conditions a reactor design shall meet to minimize the radiological
impacts associated with plant operations, as provided in 10 CFR 50.36a, “Technical
specifications on effluents from nuclear power reactors” (TN249).

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Additional details and discussion of the radiation protection regulatory requirements to be
addressed in a new reactor application, excluding Appendix I to 10 CFR Part 50 (TN249), which
only applies to LWRs, can be found in Section 3.9.1.1, Regulatory Requirements, of Revision 2

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to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear
Plants (NRC 2024-TN10161), which is incorporated by reference.

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The PPE assumes that the application contains sufficient technical information, both in scope
and depth, for the NRC staff to complete the detailed technical review and render an
independent assessment with regard to applicable regulatory requirements and the protection of
public health, safety, and security. The level of detail provided in each section of the Final
Safety Analysis Report/Preliminary Safety Analysis Report is expected to be commensurate
with the safety significance of the topic. The PPE also assumes that the staff will find the
application to be in compliance with the above regulations that will ensure that effluent release
limits will be met during normal operations for the life of the plant.

3.8.1.1.2 Radiological Exposure Pathways

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There are various environmental pathways by which radiation and radioactive effluents can be
transmitted from a reactor to living organisms, assuming there are radiological effluent releases.
The scope of this radiological health evaluation for the dose to the maximally exposed individual
(MEI) and to the population includes consideration of (1) the pathways by which gaseous and
liquid radioactive effluents can be transported to individual receptors (MEI, construction workers,
and occupational workers) along with the surrounding population, and (2) the location of these
receptors.

For the radiological gaseous effluent releases, the following exposure pathways may exist:

• immersion in airborne activity in the plume;

• inhalation of airborne activity in the plume;

• direct radiation exposure from deposited activity on the ground; and

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• ingestion of locally grown meats, fruits, vegetables, and milk from the absorption of the
released radionuclides into the production of major types of foods within 80 km (50 mi) of
the plant.

The radiological liquid effluent exposure pathways may include the following:

• ingestion of water from downstream sources;

• ingestion of aquatic organisms as food (i.e., fish and invertebrates);

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• ingestion of locally grown meats, fruits, vegetables, and milk within 80 km (50 mi) of the
plant that is irrigated by water drawn from a body of water into which the liquid effluent is
discharged; and

• radiation exposure from swimming and boating activities in the same body of water.

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Similar pathways exist to expose nonhuman biota to the radiological effluent releases from a
reactor. Radiological exposure for construction and occupational workers is expected to be from
inhalation of the airborne plume, direct radiation from deposited plume activity on the ground or
from radiation sources due to byproduct material devices used during construction, and from the
plant or other co-located nuclear facility operations. In addition, there is the potential for these
receptors to be exposed to radionuclides via the ingestion of water from downstream sources if
they are the plant’s potable water source.

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Representative diagrams of the radiological exposure pathways to be considered are provided
in Figure 3-2 for human exposure and Figure 3-3 for nonhuman exposure.

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Figure 3-2

Representative Radiological Exposure Pathways to Human.
Source: Modified from Soldat et al. 1974-TN710.

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Figure 3-3

Representative Radiological Exposure Pathways to Nonhuman Biota.
Source: Modified from Soldat et al. 1974-TN710.

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3.8.1.2

Radiological Environment Impacts

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This section characterizes the environmental impacts of the liquid and gaseous effluent
releases, the onsite radiological waste management systems, solid low-level radioactive waste
management (LLRW), and onsite storage of spent fuel. This analysis includes assessing
potential radiological impacts on construction workers as well as radiological impacts on
humans (occupational workers and members of the public) and nonhuman biota from operation
of a new reactor. Building a nuclear power station is a project that may affect construction
workers as a result of direct radiation and radiological releases from co-located operating
nuclear facilities. Radiological health impacts on occupational workers can occur from operation
of the radioactive waste systems, onsite storage of waste, and from operation of the nuclear
power station. The impacts on members of the public and nonhuman biota can come from the
ingestion of food and water, external exposure from water immersion, inhalation of airborne
radionuclides, and external exposure to immersion in gaseous effluent plume.

3.8.1.2.1 Environmental Consequences of Construction

The NRC staff identified one environmental issue associated with construction:

• radiological dose to construction workers.

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If the site for the new reactor is a greenfield site (i.e., no adjacent or nearby nuclear facilities),
then there are no potential radiation exposure pathways and no analysis of construction worker
dose is necessary. For sites that have adjacent nuclear facilities (LWRs, other reactors,
independent spent fuel storage installation [ISFSIs], nuclear research facilities, nuclear fuel
cycle facilities, etc.) that are already operational, potential sources of radiation exist that will
expose construction workers to radiation during the site preparation and construction phases of
building. Similarly, if the site for the new reactor is a brownfield site (i.e., a site characterized by
the potential presence of hazardous substances, pollutants, or contaminants; EPA 2021TN6848) potential sources of radiation exist that could expose construction workers to radiation
during the site preparation and construction phases of building. If a reactor building could hold
multiple cores, it is also assumed that once the first reactor core became critical, construction on
any other modules would be performed by properly trained and qualified radiation workers
whose radiation exposure would be controlled under the regulatory limits of 10 CFR 20.1201
(TN283).

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New reactors could be manufactured at an offsite location and either major components or, if
small enough, the complete reactor system with a fueled subcritical core, could be delivered to
the site. Thus, the onsite time required for construction and installation of a packaged reactor
system is expected to be noticeably less than that for a large LWR employing traditional
construction methods. This offsite manufacturing process reduces radiation exposures to
construction workers by reducing the amount of time they would be working near operating
units.

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Construction worker radiation doses must remain below the radiation dose limit for individual
members of the public (100 millirems/year [mrem/yr] [10 CFR 20.1301; TN283]) pursuant to
10 CFR Part 20, Subpart D (TN283), “Radiation Dose Limits for Individual Members of the
Public.” Because of the variability in new reactor designs, power levels, and timeframes for the
construction stage, the potential radiation exposure levels could range from not measurable to
close to the 100 mrem/yr regulatory limit. It is also expected that the applicant, if issued a
license, would mitigate the construction worker radiation exposures by following radiation

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protection best practices to maintain radiation dose ALARA standards in accordance with
10 CFR 20.1101 (TN283), “Radiation Protection Programs.”
New reactor licensing actions for LWRs have shown that the anticipated radiological doses to
construction workers would be within regulatory limits for members of the public, as shown in
Table 3-2. These results show that even for sites with co-located nuclear power plants, dose
levels are generally significantly below 100 mrem/yr. The only exception is for the Fermi 3
licensing action, which involved an anticipated dose slightly less than 100 mrem/yr, and this was
in part due to the type of reactor in operation at Fermi 2 and having an ISFSI adjacent to the
Fermi 3 construction site that would have a number of storage casks in place during the
construction time frame (see Section 4.9 of NRC 2013-TN6436). Therefore, it is important that
exposure pathways from any adjacent or nearby nuclear facility, whether licensed by the NRC,
an Agreement State, or if next to another Federal nuclear facility, be properly accounted for
when assessing annual doses to construction workers.

Table 3-2

Construction Worker Individual and Collective Doses
Cumulative
Individual Construction
Construction Worker Dose
Worker Worker Dose
(personPopulation (mrem/yr)
rem/yr)

Site Name
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
North Anna Power Station Unit 3 ESP (NRC 2010-TN6)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011-TN6437)
Vogtle Units 3 and 4 ESP (NRC 2008-TN673)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016-TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)

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20

3,150
3,150
3,500
3,950
5,950
3,600
3,300
4,953
3,500
2,900
2,100
4,100
2,800
3,950
3,300

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29
38.81
19
1.2
2.7
2.5
26.3
96.6
0.4
18.7
6
16.4
53

80
112
102
4.6
4.7
92
0.83
77
17
10.3
170

Based on these considerations, the NRC concludes that radiological impacts during
construction would be SMALL for all new reactors independent of power level or design and the
doses would be less than the regulatory limits, which will be demonstrated in the application.
This is a Category 1 issue. The staff relied on the following PPE assumptions to reach this
conclusion:
• For protection against radiation, the applicant must meet the regulatory requirements of:

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–

10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a
license

–

10 CFR 20.1201 Occupational dose limits for adults

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10 CFR 20.1301 Dose limits for individual members of the public

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4

–

Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs) and Derived Air
Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent
Concentrations; Concentrations for Release to Sewerage

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–

10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control
releases of radioactive material in effluents—nuclear power reactors

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10 CFR 50.36a Technical specifications on effluents from nuclear power reactors.

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• Application contains sufficient technical information for the staff to complete the detailed
technical safety review.
• Application will be found to be in compliance by the staff with the above regulations through
a radiation protection program and an effluent release monitoring program.

3.8.1.2.2 Environmental Consequences of Operation

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If the new reactor design does not have radiological gaseous and liquid effluent releases and no
significant quantities of solid radioactive waste are being stored onsite, then there are no
potential offsite radiation exposure pathways and no environmental analysis of offsite
radiological dose is necessary. To receive an NRC license, the applicant must provide
assurances that the new reactor’s operations would not exceed regulatory limits for
occupational doses and doses to individual members of the public, as set forth in 10 CFR
Part 20 (TN283). Under the safety review, the staff would review and confirm in the Final Safety
Evaluation Report that the application demonstrates adequate protection of the public’s health
and safety by meeting the appropriate regulatory limits through all operational phases. The
application’s safety analysis does not assess the collective dose to the surrounding population
or doses to nonhuman biota.

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The NRC staff identified four environmental issues related to radiological environment impacts
for operation of a new reactor:

• occupational doses to workers

• MEI annual doses

• total population annual doses

• nonhuman biota doses.

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Variability in radiological waste management systems between new reactor designs is
expected. Some new reactors may be designed to have no radiological effluent releases and
very small quantities of onsite solid radioactive waste. Other new reactors, such as liquid-fueled
molten-salt reactors, may have industrial processes for removing fission products from the
nuclear fuel as part of their normal operating procedures with accompanying releases of noble
and volatile radioactive gases, and liquid waste from processing stream(s). This would
necessitate an appropriately designed and approved 10 CFR Part 50 (TN249) or Part 52
(TN251) radioactive waste management system and an associated processing and storage
facility to support plant operations. It is also expected that the various new reactor designs with
lower power levels and inherent design features, while satisfying the regulatory limits for effluent
releases of 10 CFR Part 20 (TN283), would not necessarily have the same level of effluent
releases as the LWRs previously assessed in the new reactor ESP and COL EISs. Thus, based
on the assumption that new reactors will meet regulatory effluent release limits, the previous

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new reactor environmental impacts for LWRs would provide bounding impacts for new
reactors with radioactive waste streams leading to offsite doses.

Occupational Doses to Workers

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The licensee of a new plant would need to maintain individual doses to workers to within 5 rem
annually as specified in 10 CFR 20.1201 (TN283) and incorporate provisions to maintain doses
ALARA. Section 3.9.1.2, “Occupational Radiological Exposures,” of Revision 2 to NUREG-1437
(NRC 2024-TN10161) provides a detailed analysis of occupational doses to workers at LWR
nuclear power plants. This analysis shows improvements have been implemented over the
years of operational experience to reduce occupational doses to workers and that the average
annual doses are well within regulatory limits, and Revision 2 to NUREG-1437 (NRC 2024TN10161) is incorporated by reference.

12
13
14
15
16

New reactor applicants’ radiation protection programs should be able to build upon and apply
the lessons learned through LWR operational experience to maintain their workers’ occupational
doses well below regulatory limits and would ensure that occupational exposures are
maintained ALARA. In addition, new reactor applicants could establish plans for worker training,
monitoring, and radiation safety programs.

17
18
19
20
21
22

The staff concludes that the health impacts from occupational radiation exposure would be
SMALL based on individual worker doses being maintained within 10 CFR 20.1201 (TN283)
limits and collective occupational doses for new reactors should be in line with the radiation
protection practices at current operating LWRs. Additional mitigation would not be warranted
because the operating plant would be required to maintain doses ALARA. This is a Category 1
issue. The staff relied on the following PPE assumptions to reach this conclusion:

• For protection against radiation, the applicant must meet the regulatory requirements of:

24
25

–

10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a
license

–

10 CFR 20.1201 Occupational dose limits for adults

27
28
29

–

30
31

–

10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control
releases of radioactive material in effluents—nuclear power reactors

–

10 CFR 50.36a Technical specifications on effluents from nuclear power reactors.

33
34

• Application contains sufficient technical information for the staff to complete the detailed
technical safety review.

35
36

• Application will be found to be in compliance by the staff with the above regulations through
a radiation protection program and an effluent release monitoring program.

Maximally Exposed Individual Annual Doses

38
39
40
41

Prior new reactor EISs have assessed the total dose to the MEI as part of meeting the
requirements of the 10 CFR Part 20 (TN283) based on the methodology provided in RG 1.109,
Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose
of Evaluating Compliance with 10 CFR Part 50, Appendix I (NRC 1977-TN90). The MEI total

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2
3
4
5
6
7
8
9
10

dose is usually assessed from the nuclear power plant to the nearest resident assuming all
appropriate exposure pathways are at that location. This assumption provides for a conservative
or bounding analysis for demonstrating compliance with regulatory dose limits. Prior LWR new
reactor ESP and COL MEI annual doses are provided in Table 3-3 along with two non-LWRs,
namely the Kairos Hermes test reactor and the Abilene Christian University Molten Salt
Research Reactor. The table demonstrates that the MEI annual dose assessed not only met the
regulatory limit of 100 mrem/yr in 10 CFR 20.1301(a) (TN283) but also met the lower regulatory
limits in 40 CFR Part 190 (TN739), which is incorporated into NRC regulations under 10 CFR
20.1301(e) (TN283), even for sites with co-located nuclear power plants.
Table 3-3

Maximally Exposed Individual Doses(a)

Site Name
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
North Anna Power Station Unit 3 ESP (NRC 2010-TN6)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011-TN6437)
Vogtle Units 3 and 4 ESP (NRC 2011-TN6439)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016-TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)
Kairos Hermes construction permit (CP) (NRC 2023-TN9771)
Abilene Christian University Molten Salt Research Reactor CP
(NRC 2024-TN10337)

Total Body
(mrem/yr)(b)
3.21
8.9
6.9
0.458
5.71
2.2
5.5
3.7
2.36
5.66
3.74
2.94
7.8
4.52
11
2.4
<0.5

Thyroid
(mrem/yr)
9.47
17.0
18.0
0.88
4.55
14.0
12.9
3.1
12.39
13.99
20.0
6.86
15.0
6.80
25.0
1.7
-

Organ
(mrem/yr)
5.04
21.0
14.0
1.3
1.94
3.5
19.5
7.8
8.88
2.32
9.05
3.97
8.4
7.32
24.0
1.5
-

(a) 40 CFR 190.10 (a) (TN739) states “the annual dose equivalent does not exceed 25 millirems to the whole body,
75 millirems to the thyroid, and 25 millirems to any other organ of any member of the public as the result of
exposures to planned discharges of radioactive materials, radon and its daughters excepted, to the general
environment from uranium fuel cycle operations and to radiation from these operations.”
(b) These values meet the restrictions stated in 40 CFR 190 (a) (TN739) as well as the restrictions in 10 CFR
20.1301(a)(1) (TN283) Dose Limits.

11
12
13
14
15
16
17
18
19
20
21

A new reactor applicant must provide the necessary information on the docket for the staff to
reach a regulatory finding that the regulatory requirements have been met, such as annual dose
limits to members of the public provided in 10 CFR 20.1301 (TN283). Additionally, 10 CFR Parts
20 (TN283) and 50 (TN249) require that a REMP be established to provide data about
measurable levels of radiation and radioactive materials in the site environs. Licensees would
rely on the REMP or a similar program to satisfy the requirements of Criterion 64, “Monitoring
Radioactivity Releases,” of Appendix A, “General Design Criteria for Nuclear Power Plants,” to
10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities (NRC 2016TN6463) or applicant-developed plant-specific Principal Design Criteria for non-LWRs (NRC
2018-TN7066). Therefore, the environmental impacts on the MEI are expected to be SMALL
where new reactor applicants demonstrate in their application that any radiological effluent

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3
4

releases and annual doses would be within regulatory limits, or where the staff during their
safety review finds the applicant would be in compliance with the applicable 10 CFR Part 20
regulations. This is a Category 1 issue. The staff relied on the following PPE assumptions to
reach this conclusion:

• For protection against radiation, the applicant must meet the regulatory requirements of:

6
7

–

10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a
license

–

10 CFR 20.1301 Dose limits for individual members of the public

9
10
11

–

12
13

–

10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control
releases of radioactive material in effluents—nuclear power reactors

–

10 CFR 50.36a Technical specifications on effluents from nuclear power reactors.

15
16

• Application contains sufficient technical information for the staff to complete the detailed
technical safety review.

17
18

• Application will be found to be in compliance by the staff with the above regulations through
a radiation protection program and an effluent release monitoring program.

Total Population Annual Doses

20
21
22
23
24
25
26
27
28
29
30
31

If there are radiological effluent releases, they will move beyond the site into the surrounding
area exposing the surrounding population, and the impacts from such releases need to be
assessed under NRC’s NEPA obligations. For the past new reactor ESP and COL application
reviews, this analysis of total population doses was provided using the NRCDose code, which
was also applied as part of the safety analysis and was evaluated out to a distance of 80 km
(50 mi.). These total population dose results from the various ESPs and COLs approved by the
NRC are provided in Table 3-4. As part of these reviews, the staff compared the total population
dose associated with the licensing action to the collective dose from natural background
radiation based on an average annual individual natural background dose of 310 mrem/yr. The
results from the various ESP and COL radiological assessments show that the surrounding
population would receive a very small fraction of what would be expected from natural
background.

32
33
34
35
36
37
38

Both the NCRP and the International Council on Radiation Protection and Measurements
(ICRP) suggest that when the collective effective dose is smaller than the reciprocal of the
relevant risk detriment (i.e., less than 1/0.00057, which is less than 1,754 person-rem), the
assessment should find that the most likely number of excess health effects is zero (NCRP
1995-TN728; ICRP 2007-TN422). As noted above, all of the ESP and COL total population
doses are significantly less than the 1,754 person-rem value that both ICRP and NCRP suggest
would most likely result in zero excess health effects (NCRP 1995-TN728; ICRP 2007-TN422).

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Table 3-4

Total Population and Collective Natural Background Doses in 50 mi Radius(a)

50 mi
Population

Site Name
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
North Anna Power Station Unit 3 ESP (NRC 2010-TN6)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011-TN6437)
Vogtle Units 3 and 4 ESP (NRC 2011-TN6439)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016-TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)

Collective
50 mi
Dose from
Population
Natural
Collective Background
Dose
Radiation
(person(personrem/yr)
rem/yr)

800,000
332,369
2,800,000
6,418,570
514,000
2,131,394
1,440,000
3,490,000
674,101
7,710,000
4,195,000
8,138,635
7,500,000
2,640,368
2,658,157

1.83
3.20
8.70
3.9
0.58
34.50
13.8(a)
8.00
1.84
21.60
10.6
65.90
8.00
8.54
68.00

230,000
102,000
840,000
2,000,000
160,000
663,000
520,000
985,000
243,000
2,400,000
1,305,000
2,531,000
2,500,000
821,154
830,000

(a) The 50 mi population collective dose for one unit was multiplied by 2 to account for a two-unit site.

2
3
4
5
6
7
8
9

The combination of these radiological impacts demonstrates a low MEI dose correlates to a
small total population dose, even out to 80 km (50 mi.), where zero excess health effect in the
general population would be expected. Therefore, the environmental impacts on the
surrounding population are expected to be SMALL where new reactor applicants demonstrate in
their application that any radiological effluent releases and annual doses to the population would
be within regulatory limits of 10 CFR Part 20 (TN283). This is a Category 1 issue. The staff
relied on the following PPE assumptions to reach this conclusion:
• For protection against radiation, the applicant must meet the regulatory requirements of:

10
11

–

10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a
license

–

10 CFR 20.1301 Dose limits for individual members of the public

13
14
15

–

16
17

–

10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control
releases of radioactive material in effluents—nuclear power reactors

–

10 CFR 50.36a Technical specifications on effluents from nuclear power reactors.

19
20

• Application contains sufficient technical information for the staff to complete the detailed
technical safety review.

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2

Application will be found to be in compliance by the staff with the above regulations through a
radiation protection program and an effluent release monitoring program.

Nonhuman Biota Doses

4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

The Commission position on nonhuman biota doses is that the current set of radiation protection
controls is protective of the environment. Therefore, the NRC radiation protection regulations, by
protecting members of the public, also protect nonhuman biota and there is no need to have
separate radiation protection regulations for plant and animal species (SECY-04-0223 [NRC
2004-TN6431], SECY-06-0168 [NRC 2006-TN6430], SECY-08-0197 [NRC 2008-TN6432],
SECY-04-0055 [NRC 2004-TN7100], and related Staff Requirements Memorandums SRMSECY-04-0223 [NRC 2005-TN6649], SRM-SECY-06-0168 [NRC 2005-TN6650], SRM-SECY08-0197 [NRC 2009-TN6651]), SRM-SECY-04-0055 [NRC 2004-TN7101]. The IAEA (1992TN712) and the NCRP (1991-TN729) report that a chronic dose rate of no greater than
10 milligrays/day (mGy/d) (1,000 millirads/day [mrad/d]) to the MEI in a population of aquatic
organisms would ensure protection of the population. The IAEA (IAEA 1992-TN712) also
concluded that chronic dose rates of 1 mGy/d (100 mrad/d) or less do not appear to cause
observable changes in terrestrial animal populations. These two guidelines (1,000 mrad/d for
aquatic biota, 100 mrad/d for terrestrial biota) have been applied in various NRC environmental
reviews. For example, the impact of radionuclides on aquatic organisms has been raised as an
issue by the public for several of the nuclear plants that have undergone license renewal. The
License Renewal GEIS Revision 1 (NRC 2024-TN10161) concludes that the impact of routine
radionuclide releases from past and current operations on aquatic and terrestrial biota would be
SMALL for all nuclear plants and would not be expected to appreciably change during the
renewal period.

24
25
26
27
28
29
30
31
32
33
34

Nonhuman biota doses have also been assessed in the new reactor ESP and COL FEISs. The
results from the new reactor reviews for the seven surrogate species (three aquatic species and
four terrestrial species analyzed within the NRCDose code) are shown in Table 3-5 and
Table 3-6. These tables clearly show the absorbed dose rates for all surrogate species were
much lower than the IAEA and NCRP guidelines (IAEA 1992-TN712; NCRP 1991-TN729).
Thus, the conclusion in all of the new reactor environmental reviews was the radiological impact
on nonhuman biota from a new nuclear power plant at the selected site would be SMALL.
Therefore, the environmental impacts on nonhuman biota are expected to be SMALL where
new reactor applicants demonstrate in their application that any radiological effluent releases
and annual doses would be within regulatory limits. This is a Category 1 issue. The staff relied
on the following PPE assumption to reach this conclusion:

35
36

• Applicants would demonstrate in their application that any radiological nonhuman biota
doses would be below IAEA (1992-TN712) and NCRP (1991-TN729) guidelines.

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Table 3-5

Aquatic Nonhuman Biota Doses(a)

Site Name
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
North Anna Power Station Unit 3 ESP (NRC 2010-TN6)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011-TN6437)
Vogtle Units 3 and 4 ESP (NRC 2011-TN6439)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016-TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)

Fish
(mrad/d)
0.0171
0.068(b)
0.009(b)
0.00077
0.0068
0.0022
0.01
0.052
0.00044(c)
0.0063
0.0016
0.0045
0.00
0.00052
0.0045

Invertebrate
(mrad/d)
0.0376
0.452(b)
0.033(b)
0.0064
0.015
0.0063
0.02
0.088
0.0012(c)
0.021
0.0044
0.0161
0.00
0.0018
0.021

Algae
(mrad/d)
0.0762
0.405(b)
0.047(b)
0.015
0.0015
0.018
0.03
0.11
0.0036(c)
0.033
0.013
0.0225
0.00
0.0058
0.0067

(a) The IAEA and NCRP reported a chronic absorbed dose rate of no greater than 1,000 mrad/d would ensure
protection of aquatic organism populations (IAEA 1992-TN712; NCRP 1991-TN729).
(b) Dose converted from mGy/yr to mrad/d.
(c) Dose converted from mGy/d to mrad/d.

Table 3-6

Terrestrial Nonhuman Biota Doses(a)

Site Name
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
North Anna Power Station Unit 3 ESP (NRC 2010-TN6)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011-TN6437)
Vogtle Units 3 and 4 ESP (NRC 2011-TN6439)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016-TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)

Muskrat Racoon Heron
Duck
(mrad/d) (mrad/d) (mrad/d) (mrad/d)
0.0471
0.0222
0.191
0.0470
(b)
(b)
(b)
0.227
0.058
0.534
0.227(b)
(b)
(b)
(b)
0.112
0.056
0.082
0.112(b)
0.0038
0.00075 0.0011
0.0038
0.03
0.031
0.03
0.036
0.020
0.023
0.044
0.027
0.02
0.01
0.01
0.02
0.19
0.060
0.55
0.19
(c)
(c)
(c)
0.0055
0.0066
0.01
0.0071(c)
0.071
0.032
0.049
0.071
0.016
0.011
0.030
0.015
0.0199
0.0170
0.0203
0.0206
0.14
0.14
0.14
0.14
0.010
0.0090
0.013
0.010
0.24
0.23
0.25
24

(a) The IAEA concluded that a chronic absorbed dose rate of 100 mrad/d or less does not appear to cause
observable changes in terrestrial animal populations (IAEA 1992-TN712).
(b) Dose converted from mGy/yr to mrad/d.
(c) Dose converted from mGy/d to mrad/d.

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3.8.2

3.8.2.1

Nonradiological Environment
Baseline Conditions and PPE/SPE Values and Assumptions

3
4
5
6
7
8
9
10
11
12
13
14
15

Baseline conditions influencing potential public and occupational health impacts associated with
the building and operation of a new reactor include consideration of nonradiological chemical
hazards, biological hazards, EMFs, the distance to receptors (occupational workers or a
member of the public), the number of people potentially exposed, and other industrial physical
concerns, such as falls, burns from high temperature, shock, or asphyxiation. Relevant public
and occupational health conditions involve not only industrial processes at the plant itself, but
also consider other sources of public and occupational exposure, such a neighboring chemical
facilities and current road conditions. Section 3.3 includes information about air quality.
Section 3.4 includes information about water resources. Section 3.9 includes information about
noise. Section 3.11 includes information about postulated accidents. Section 3.12 includes
information about traffic impacts. Section 3.15 includes information about transportation of fuel
and waste, while Section 3.10 includes information about waste impacts. The overall well-being
of these resource areas is important to maintaining the quality of public and occupational health.

16
17
18

The assumption of the PPE/SPE developed for this GEIS is that the applicant must adhere to
applicable Federal, State, local and tribal public and occupational health regulatory limits and
BMPs regarding chemical hazards, biological hazards, EMFs, and physical hazards.

3.8.2.1.1 Chemical Hazards

20
21
22
23
24
25
26

A chemical hazard occurs when workers or members of the public are exposed to a
nonradiological hazardous substance by inhalation, skin absorption, or ingestion. Chemical
hazards can have immediate effects (nausea, vomiting, acid burns, asphyxiation—also known
as acute hazards) or the effects might take time to develop (dermatitis, asthma, liver damage,
cancer—also known as chronic hazards). Figure 3-2 shows the exposure pathways for
radiological hazards to humans. Those same exposure pathways also apply to nonradiological
chemical hazards to humans.

27
28
29
30
31
32

For large LWRs, there are multiple pathways by which humans can be exposed to pollutants
from a plant. For example, a direct pathway would be a human breathing in a gaseous effluent
or swimming in water that was contaminated by a liquid effluent. An indirect pathway would be a
human eating a fish that had absorbed a pollutant into its body or eating crops that had been
irrigated with water contaminated by a liquid effluent. One advantage of a new reactor is that
pathways for exposure could be limited based on the design.

33
34
35
36
37
38
39
40
41
42
43
44

The Occupational Safety and Health Administration is responsible for developing and enforcing
workplace safety regulations. Congress created the Occupational Safety and Health
Administration by enacting the Occupational Safety and Health Act of 1970, as amended (29
U.S.C. 651 et seq.) to safeguard the health of workers. Nuclear power plant conditions that
result in an occupational risk, but do not affect the safety of licensed radioactive materials, are
under the statutory authority of the Occupational Safety and Health Administration rather than
the NRC as set forth in a memorandum of understanding (NRC 2013-TN10165) between the
two agencies. The Occupational Safety and Health Administration rather than the NRC as set
forth in a memorandum of understanding (NRC 2013-TN10165) between the two agencies. The
Occupational Safety and Health Administration sets enforceable permissible exposure limits for
about 500 hazardous chemicals to protect workers against the health effects of exposure to
hazardous substances, including limits on the airborne concentrations of hazardous chemicals

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2
3

in the air and skin contact. Most permissible exposure limits are 8-hour time-weighted averages,
although there are also ceiling and peak limits. Regulatory limits for chemical hazards are found
in 29 CFR Part 1910 (TN654).

4
5
6
7
8
9
10
11
12

The EPA is responsible for the regulation of most chemicals that can enter the environment
through the following Federal Acts: the Federal Insecticide, Fungicide, and Rodenticide Act
(7 U.S.C. §§ 136 et seq.; TN4535); Toxic Substances Control Act (15 U.S.C. §§ 2601 et seq.;
TN4454); RCRA (42 U.S.C. §§ 6901 et seq.; TN1281); Clean Water Act (codified as the Federal
Water Pollution Control Act of 1972; 33 U.S.C. §§ 1251 et seq.; TN662); SDWA (42 U.S.C.
§§ 300f et seq.; TN1337); Clean Air Act (42 U.S.C. §§ 7401 et seq.; TN1141); and the
Comprehensive Environmental Response Compensation and Liability Act (42 U.S.C. §§ 9601
et seq.; TN6592). Discharged biocides, liquid wastes, chemicals, and heavy metals are
regulated by the NPDES permitting system.

3.8.2.1.2 Biological Hazards

14
15
16
17
18
19
20
21
22
23

Biological hazards are organic substances that pose a threat to the health of humans and other
organisms. Biological hazards include pathogenic microorganisms, insects, animals, viruses,
toxins, spores, and fungi. Biological hazards, such as mosquitos, bees, and ticks could be
present at any industrial site, either while building the facility itself or while the facility is in
operation. Microbiological hazards occur when workers or members of the public come into
contact with disease-causing microorganisms, also referred to as etiological agents. Examples
of etiological agents are Salmonella spp., Shigella spp., Legionella spp., Pseudomonas
aeruginosa, or thermophilic fungi. NUREG-1437, Volume 1, Revision 1 (NRC 2024-TN10161),
provides further background information about microorganisms of concern at large LWRs and a
description of studies of microorganisms in cooling towers.

3.8.2.1.3 Electromagnetic Fields

25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40

An EMF is caused by a combination of electric and magnetic fields of force or moving electric
charges. The strength of the EMF will increase with an increase in voltage. EMFs are generated
by natural phenomena (for example the Earth’s magnetic field) or any electrical equipment
(WHO 2020-TN6561). There are no U.S. Federal standards limiting residential or occupational
exposure to EMFs from power lines, but some states, such as Florida, Minnesota, Montana,
New Jersey, New York, and Oregon, have set electric field and magnetic field standards for
transmission lines (NIEHS 2002-TN6560). EMFs resulting from a 60 Hz power transmission line
falls under the category of non-ionizing radiation. A voluntary occupational standard has been
set for EMFs by the International Commission on Non-Ionizing Radiation Protection. For
occupational workers who are exposed to 60 Hz (power lines), the electric field standard is
8.3 kV/m and the magnetic field standard is 4,200 milligauss, while for the general public who
are exposed to 60 Hz, the electrical field standard is 4.2 kV/m and the magnetic field standard is
833 milligauss (ICNIRP 1998-TN6591). The National Institute of Occupational Safety and Health
does not consider EMFs to be a proven health hazard (NIOSH 1996-TN6766). NUREG-1437,
Volume 1 (NRC 2024-TN10161), provides further background information about EMFs at large
LWRs.

41
42
43
44

In 1996, the World Health Organization began a multidisciplinary research study regarding the
possible health effects from exposure to EMF sources (WHO 2020-TN6561) and concluded
current evidence does not support the existence of any health consequences from exposure to
low-level EMFs. Two additional reports, one from the U.S. National Academy of Science

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2

(National Research Council 1997-TN6595), and another from the National Institute of
Environmental Health Sciences, concluded similar findings (NIEHS 2002-TN6560).

3.8.2.1.4 Physical Hazards

4
5
6
7
8
9
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A physical hazard is an action, agent, or condition that can cause harm upon contact. Physical
hazards include actions such as slips, trips, and falls. Physical hazards from agents include
noise (see Section 3.9), shock, vibration, ionizing radiation, and ergonomic factors from heavy
lifting and repetitive motion. Physical conditions could include high heat, cold, pressure, or
confined space. A new reactor is an industrial facility and will have many of the typical
occupational hazards found at other electric power generation utilities. Physical hazards such as
ladder safety, fall protection, noise exposure, non-ionizing radiation, and personal protective
equipment are regulated by 29 CFR Part 1910 (TN654).

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If a new reactor were to be a power-producing facility, transmission lines to support the power
grid would be necessary. Occupational workers and members of the public could be exposed to
acute electric shock from transmission lines or electrical equipment needed to support the
facility. Secondary shock currents are also produced when humans make contact with
(1) capacitively charged bodies, such as a vehicle parked near a transmission line, or
(2) magnetically linked metallic structures, such as fences near transmission lines. The National
Electrical Safety Code contains the basic provisions that are considered necessary for the
safety of employees and the public under specific conditions. 29 CFR 1926 Subpart V (TN4455)
contains safety regulations related to electrical power transmission and distribution.
NUREG-1437, Volume 1 (NRC 2024-TN10161), provides further information about electric
shock.

3.8.2.2

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The NRC has assessed the impacts on nonradiological public and occupational health from the
existing operating reactor fleet during license renewal assessments and from proposed new
reactors as part of the COL and ESP process under 10 CFR Part 52 (TN251). Impacts on
nonradiological public and occupational health from the continued operation and refurbishment
of typical large LWRs in the existing U.S. fleet are evaluated in the License Renewal GEIS
(NRC 2024-TN10161). Impacts from the building and operation of new reactors have been
evaluated in several EISs. The NRC staff assumes that the impacts on nonradiological public
and occupational health from the construction and operation of new reactors would generally be
bounded by the large LWRs.

3.8.2.2.1 Environmental Consequences of Construction

The NRC staff identified two environmental issues:

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Nonradiological Environment Impacts

• building impacts of chemical, biological, and physical nonradiological hazards, and
• building impacts of EMFs.
The primary impacts of constructing a new reactor on nonradiological public and occupational
health would be from building activities. Potential occupational worker impacts would come from
chemical hazards, biological hazards, EMFs, and physical hazards typical of large-scale
building construction. This would include exposure to the following:
• equipment engine exhaust

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• heavy metals in solder or welding fumes

• solvent vapors

• fugitive dust

• plant toxins, insects, and other biological hazards

• vibration

• slips, trips, falls from scaffolding

• heat or cold stress, burns, frost-bite

• noise (see Section 3.9 regarding information about this subject)

• heat stress

• non-ionizing radiation from welding

• shock from electrical equipment

• repetitive motion (ergonomic concerns), strains, and sprains

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• traffic-related impacts from construction worker and supply transportation (see Section 3.12
regarding information about this subject).

Building Impacts of Chemical, Biological, and Physical Nonradiological Hazards

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Chemical exposure would exist in the form of dust, fumes, fibers (solids), liquids, mists, gases,
or vapors. Examples of chemical hazards found in construction work could include lead, silica,
cadmium, carbon monoxide, oxides of nitrogen, VOCs, welding fumes, spray paints, cutting oil
mists, solvents, and hexavalent chromium. Fugitive emissions of dust in particular would be
generated during windy periods, earthmoving, and movement of vehicular traffic over recently
disturbed areas. Exposure to plant and insect toxins could occur during earthmoving activities.
Physical impacts common to any large-scale industrial project would also occur.

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Potential impacts on members of the public during building would be from chemical hazards and
physical hazards typical of large-scale building construction. This would include exposure to
some of the hazards that occupational workers would face, such as equipment engine exhaust,
fugitive dust, vibration, noise, and traffic-related impacts from construction worker and supply
transportation. Members of the public could be exposed to building impacts due to the proximity
of their house, work, school, recreational site, or via a water source. Applicable liquid and air
permits and regulations would also regulate impacts on members of the public, similar to the
regulation for occupational workers.

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Occupational and public health mitigation measures that may be used to reduce potential
impacts during building, include phasing activities and equipment use; BMPs such as proper
equipment maintenance and use; and watering and stabilizing roads and spoils.

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Building activities are typically subject to air permits under State and Federal laws to address
impacts of air emissions on any local sensitive receptors. Mitigation could also consist of
providing administrative and engineering design features, such as dikes around large liquid
chemical tanks.

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The staff has determined that nonradiological public and occupational health impacts associated
with chemical, biological, and physical hazards during construction of a new reactor are a
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Category 1 issue. The staff concluded that as long as the applicable PPE and SPE values and
assumptions are met, the nonradiological public and occupational health impact from building a
new reactor can be generically determined to be SMALL. Any planned exposure or release over
the regulatory limit would require project-specific analysis. The staff relied on the following PPE
values and assumptions to reach this conclusion:

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• The applicant must adhere to all applicable Federal, State, local or Tribal regulatory limits
and permit conditions for chemical hazards, biological hazards, and physical hazards.

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• The applicant will follow nonradiological public and occupational health BMPs and mitigation
measures, as appropriate.

Building Impacts of EMFs

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Occupational workers would be exposed to EMFs during the use of any electronic tool or
equipment. However, the staff has determined that nonradiological public and occupational
health impacts from EMFs during construction are uncertain.

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Studies of 60 Hz EMFs have not uncovered consistent evidence linking harmful effects with field
exposures. Because the state of the science is currently inadequate, no generic conclusion on
human health impacts is possible. If, in the future, the Commission finds that a general
agreement has been reached by appropriate Federal health agencies that there are adverse
health effects from EMFs, the Commission will require applicants to submit plant-specific
reviews of these health effects as part of their application. Until such time, applicants are not
required to submit information about this issue.

3.8.2.2.2 Environmental Consequences of Operation

The NRC staff identified two environmental issues:

• operation impacts of chemical, biological, and physical nonradiological hazards, and

• operation impacts of EMFs.

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The primary impacts of operating a new reactor on nonradiological public and occupational
health would be from chemical hazards, biological hazards, EMFs, and physical hazards.
Hazards present during operation for occupational workers would be the same as those listed
for construction.

Operation Impacts of Chemical, Biological, and Physical Nonradiological Hazards

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For new reactors, operations-related chemical hazards could result from the releases of liquid
effluents or gaseous emissions from industrial operations, sanitary discharges, leaching of
heavy metals from tanks or pipes, and improper storage or handling of chemicals. Various
reactor operational systems may require treatment using chemicals or biocides to avoid scaling.
The rate of flow into water systems would be managed, while facility discharges that may
contain low-level concentrations of chemicals or biocides, would be managed through
engineering and administrative controls necessary to maintain requirements of an NPDES
permit or other standards. Industrial processes at a new reactor could also use backup diesel
generators, boilers, cooling condensers, or cooling towers. Impacts on occupational workers
can result from operations of engine-driven equipment, although these types of operations may
be reduced, limited, or not present for some new reactor designs. The regulations in 10 CFR
Part 50 (TN249) dictate that safety-related diesel generators and other emission-releasing

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equipment be tested throughout the year for various durations. Diesel generators that function
as standby equipment would also typically be tested throughout the year for various durations.
Primary cooling systems, operation of process equipment, mobile emissions, and emergency
power supply systems would all release either a liquid effluent or gaseous emission. Emissions
could include nitrogen oxide, carbon monoxide, sulfur dioxide, VOCs, and particulate matter,
depending upon the plant design. Additionally, new reactors would either have a stand-alone
sanitary system or connect to a municipal sanitary system.

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Chemical effects could also be caused by the improper storage or handling of chemicals or
waste. For example, improper storage of acids and bases, chemicals commonly used in onsite
laboratories for testing of effluents, could cause an explosion. In addition, there could be
impacts from accidental chemical spills either in the laboratory or when chemistries of the
primary and secondary coolant systems are being adjusted, if multiple coolant systems are part
of the reactor design.

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Occupational workers would be exposed to biological hazards at a new reactor, as workers at
any industrial facility would be. The staff assumes the applicant to employ industry BMPs to
minimize biological hazards to occupational workers.

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Conditions at cooling towers, spent fuel pools, and other thermal discharges could provide ideal
living conditions for etiological agents unless those conditions are managed properly.
Occupational workers could come into contact with microbiological hazards when cleaning
condenser tubes or cooling towers. Management of microbiological hazards could include the
use of engineering and administrative controls, such as PPE. NUREG-1437, Volume 1, provides
an impact description of microorganisms of concern at large LWRs (NRC 2024-TN10161). The
impacts of microbiological hazards would be expected to be similar at a new reactor if the
reactor design operates with similar conditions (cooling ponds, lakes, canals or discharge to a
river). However, the NRC staff assumes that some new reactor designs will minimize the use of
cooling ponds, lakes, canals or discharges to rivers and will adhere to a NPDES permit.

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Physical hazards from actions such as slips, trips, falls from ladders, forklift operation, burns
from high temperatures, and electrical shock would be present for occupational workers.
Physical agents, such as noise (see Section 3.9), vibration, and ionizing radiation, and
ergonomic factors from heavy lifting and repetitive motion would also be expected. Occupational
workers could face potentially hazardous physical conditions, such as high heat, cold, pressure,
or performing work in confined spaces or using electrical equipment. Regulations in 29 CFR
Part 1910 (TN654) have been set in place to minimize physical hazards. The staff assumes
BMPs will be put in place by the applicant, and that the applicant will adhere to the regulations
in 29 CFR Part 1910 for nonradiological occupational health.

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Potential impacts on members of the public during operation from chemical hazards, biological
hazards, and physical hazards at a new reactor would be those typical of large LWRs and
electric power generating facilities. Hazards present during operation for members of the public
are the same as those listed for building, with the addition of planned or accidental chemical
releases from industrial processes.

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Members of the public could be exposed to operation impacts due to the proximity of their
house, work, school, recreational site, or via a water source. Applicable liquid and air permits
and regulations would also regulate impacts on members of the public, similar to the regulation
for occupational workers. The staff assumes that proper emergency management procedures
will be put in place.

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Members of the public could come into contact with microbiological hazards if in contact with a
water body that receives runoff or discharge from a new reactor or air deposition from gaseous
releases. Changes in microbial populations and in the public use of water bodies might be
caused by the operation of a new reactor that uses water as a coolant or a moderator. The staff
assumes an applicant would use advanced system designs, distance, dilution, and security
measures to minimize microbiological hazards to the public and adhere to NPDES permit
limitations.

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The scope of the transmission line review is from the plant to the first interconnecting point or
points on the existing high-voltage transmission system (NRC 2000-TN3549). The greatest
hazard from a transmission line is direct contact with the conductors. There is a potential for
members of the public to be exposed to acute electrical shock from these lines. The issue of
electrical shock is generic to all electrical power plants. Tower designs preclude direct public
access to the conductors. However, electrical contact can be made without physical contact
between a grounded object and the conductor. A person who contacts a metallic structure or a
charged object could receive a secondary shock and experience a painful sensation at the point
of contact. The staff assumes the applicant would construct and operate transmission lines in
adherence with the National Electrical Safety Code criteria (IEEE 2023-TN10132).

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Occupational and public health mitigation measures that may be used to reduce potential
impacts during operation, include adherence to industrial hygiene and safety practices and
locating noisy equipment away from sensitive receptors.

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The staff has determined that the impacts of nonradiological public and occupational health
impacts associated with chemical, biological, and physical hazards during operation is a
Category 1 issue. The staff concluded that as long as the applicable PPE and SPE values and
assumptions are met, the nonradiological public and occupational health impact from operating
a new reactor can be generically determined to be SMALL. Any planned exposure or release
over the regulatory limit would require project-specific analysis. The staff relied on the following
PPE values and assumptions to reach this conclusion:

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• The applicant must adhere to all applicable Federal, State, local or Tribal regulatory limits
and permit conditions for chemical hazards, biological hazards, and physical hazards.

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• The applicant will follow nonradiological public and occupational health BMPs and mitigation
measures, as appropriate.

Operation Impacts of EMFs

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Occupational workers would be expected to be exposed to low-frequency EMFs at a new
reactor if the primary purpose of the facility is to produce electrical power and electrical
equipment would be present. The median magnetic field measurement during a workday for a
distribution substation worker at an electric utility is 7.2 milligauss (NIEHS 2002-TN6560). The
staff assumes that occupational workers at a new reactor would experience similar fields.
Distance and shielding have been shown to be effective mitigation tools for EMFs. Members of
the public could also be exposed to EMFs from powerlines associated with the reactor.
However, the staff has determined that nonradiological public and occupational health impacts
from EMFs during operation are uncertain.

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agreement has been reached by appropriate Federal health agencies that there are adverse
health effects from EMFs, the Commission will require applicants to submit plant-specific
reviews of these health effects as part of their application. Until such time, applicants are not
required to submit information on this issue.

3.9

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This section describes the baseline conditions, PPE/SPE values, and environmental
consequences associated with noise, as heard by humans. Wildlife-related noise impacts are
described in Section 3.5.

3.9.1

Noise

Baseline Conditions and PPE/SPE Values and Assumptions

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Noise levels associated with the building and operation of a new reactor (and associated
transmission line ROWs) that may influence human health include the volume and duration of
the noise, the distance to receptors (where dwelling units or other sites of frequent human use
exist), and landscape characteristics such as topography and foliage. Noise from nuclear plant
building and operations can often be detected offsite relatively close to the plant site boundary.
Major sources of noise during building include earthmoving activities and building of safety- and
non-safety-related facilities. Major sources of noise at operating nuclear power plants are
cooling towers, turbines, transformers, large pumps, and cooling-water system motors.

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Sound pressure levels are typically measured by using the logarithmic decibel scale. To assess
potential noise impacts on humans, a special weighting scale was developed to account for
human sensitivities to certain frequencies and duration of sounds. The dBA is widely used in
environmental noise assessments because it correlates well with a human’s subjective reaction
to sound (Cowan 1994-TN3905).

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U.S. Department of Housing and Urban Development regulations for exterior noise standards
(24 CFR 51.101(a)(8); TN1016), Section 5.3.4 of NUREG-1555 (NRC 2000-TN614) states noise
levels are acceptable (i.e., SMALL) if the day-night average sound level outside a residence is
less than 65 dBA. Threshold noise levels from industrial sites are subject to threshold values
from the National Institute for Occupational Safety and Health under the Occupational Safety
and Health Act of 1970 (Public Law 91-596; 29 U.S.C. §§ 651 et seq.; TN4453). Noise
abatement issues are also handled by State and local governments because there is no
overarching Federal noise abatement program.13 The assumption underlying the PPE is that the
new reactor will not exceed a 65 dBA threshold at the site boundary, unless a relevant State or
local noise abatement law or ordinance sets a different threshold, which would then be the
presumptive threshold for PPE purposes. If an applicant cannot meet the 65 dBA threshold
through mitigation, then the applicant must obtain a variance or exception from the relevant
State or local regulator. Based upon the NRC’s past experience reviewing new reactor and
license renewal applications for large LWRs, noise impacts during both building and operation
have generally not exceeded 65 dBA (except for very short periods of time such as alarm and
equipment testing) or these impacts have been successfully mitigated (e.g., through the
implementation of BMPs, including modeling, foliage planting, building of noise buffers, and the
timing of construction activities). Therefore, the PPE assumes that applicable BMPs and

In the 1970s, the EPA coordinated all Federal noise control activities pursuant to the Noise Control Act of 1972 (42
U.S.C. §§ 4901 et seq.; TN4294), as amended by the Quiet Communities Act of 1978 (TN7029). The EPA’s
implementing regulations are at 40 CFR Parts 201 to 211 (TN7030). The EPA phased out the program’s funding in
1982 and transferred the primary responsibility of regulating noise to State and local governments.

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potential mitigation measures would be applied to reduce noise impacts to below a 65 dBA
threshold on applicable receptors, particularly during building.

3.9.2

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Noise impacts associated with new reactors and associated transmission line ROWs would take
place during the building and operation phases of the project. The mitigation measures that
could be conducted to be able to rely on the generic analysis may include implementation of
BMPs, such as modeling, foliage planting, building noise buffers, and the timing of building
and/or operation activities.

3.9.2.1

Noise Impacts

Environmental Consequences of Construction

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Impacts would occur during site preparation and the building of both safety-related and nonsafety-related facilities. Some smaller new reactor designs can be placed in one or a few small
buildings on a small site and may lack structures such as cooling towers, switchyards, or offsite
pipelines. As a result, the noise associated with building new reactors could produce lower
overall noise impacts relative to what has been typical for a large LWR. Larger new reactors
may require the building of facilities similar to those associated with a large LWR and most likely
have noise levels similar to those of a large LWR.

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In certain cases, sound modeling in accordance with industry standards may be necessary to
estimate noise levels associated with the building of the reactor. While post-mitigated noise
associated with construction may exceed the noise thresholds during certain activities, these
impacts are expected to be temporary and short in duration. As part of the ER, the applicant
should conduct a noise survey in the relevant area, identify the peak day and night noise levels
in dBA at each survey point, and establish the likely source of that noise level (e.g., road traffic,
industrial and construction noises, etc.). Therefore, the NRC staff concludes that buildingrelated human noise impacts from a new reactor would be SMALL and a Category 1 issue. The
staff relied upon the following PPE assumptions to reach this determination:

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• If an applicant cannot meet the 65 dBA threshold through mitigation, then the applicant must
obtain a various or exception with the relevant State or local regulator.

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• The project would implement BMPs, including such as modeling, foliage planting,
construction of noise buffers, and the timing of construction and/or operation activities.

3.9.2.2

Environmental Consequences of Operation

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Impacts associated with the operation of the new reactor would also occur. However, the noise
associated with the operation of the reactor, while longer in duration, is expected to be
generated at a lower level than during building. Therefore, building-generated noise impacts
establish the upper bound for operations-related noise.

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The NRC staff assumes that the noise associated with the operation of a new reactor would be
mitigated and would not routinely exceed 65 dBA at the site boundary. Therefore, the NRC staff
concludes that operation-related human noise impacts from a new reactor would be SMALL and
a Category 1 issue. The NRC staff assumes that any mitigation necessary to achieve the noise
thresholds from construction would remain in place and that no additional mitigation would be
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needed to maintain those thresholds for the duration of operations. The staff relied upon the
following PPE assumptions to reach this determination:

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• If an applicant cannot meet the 65 dBA threshold through mitigation, then the applicant must
obtain a various or exception with the relevant State or local regulator.

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• The project would implement BMPs, including such as modeling, foliage planting,
construction of noise buffers, and the timing of construction and/or operation activities.

3.10 Waste Management

3.10.1 Radiological Waste Management

3.10.1.1

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There are three types of radiological wastes that could be associated with a new reactor: LLRW
(low-level radioactive waste), high-level radioactive waste, and mixed wastes. Regulations
regarding the how a licensee shall dispose of licensed materials is regulated in accordance with
10 CFR Part 20 (TN283) Subpart K. These wastes are described in the sections below.

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The NRC staff assumes that a new reactor could be installed at an existing licensed facility. The
new reactor could be a physically separate nuclear facility or, if there is adequate land, it could
be 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 could
likely support the additional radiological wastes generated by the new reactor. For an existing
site, information should be available about the radiological waste management facilities onsite,
such as the information developed for that facility’s NRC licensing activities and documented,
for example, in annual environmental monitoring reports. This and other applicable
documentation can be incorporated by reference into the SEIS.

3.10.1.1.1 Low-Level Radioactive Wastes

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The Commission's licensing requirements for the land disposal of LLRW are set forth in 10 CFR
Part 61 (TN252), Licensing Requirements for Land Disposal of Radioactive Waste. Part 61
defines LLRW as “radioactive waste not classified as high-level radioactive waste [HLRW],
transuranic [TRU] 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.”14 The
NRC’s regulation 10 CFR 61.55 (TN252) established a classification system that categorizes
LLRW as Class A, B, C, or Greater Than Class C (GTCC). Class A wastes contain
radionuclides at relatively low concentrations, whereas the half-lives and concentrations of
radionuclides in the Class B and C wastes are progressively higher. In addition, Class B wastes
must meet more rigorous requirements with regard to their form to ensure their stability after
disposal (e.g., by adding chemical stabilizing agents such as cement to the waste or placing the
waste in a disposal container or structure that provides stability after disposal). Class C wastes
must not only meet the more rigorous requirements above but also require the implementation
14

Baseline Conditions and PPE/SPE Values and Assumptions

10 CFR 61.2 (TN252) (definition of “waste”).

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of additional measures at the disposal facility to protect against inadvertent intrusion (e.g., by
increasing the thickness and hardness of the cover over the waste disposal cell). GTCC is
LLRW with concentrations of radionuclides that exceed the limits established by the
Commission for Class C LLRW (NRC 2019-TN6440). Under the NRC’s current regulations,
GTCC 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) (TN252).
These regulations form the basis for the PPE guidance in Appendix G of this GEIS.

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For this GEIS, the NRC staff assumes that the quantities of LLRW generated at a new reactor
would be less than the quantities of LLRW generated at existing nuclear power plants, which
generate an average of 21,200 ft 3 (600 m3) and 2,000 curies (Ci) (7.4 × 1013 Bq) per year for
boiling water reactors and half that amount for pressurized water reactors (NRC 2024TN10161). The LLRW generated at a new reactor would likely be similar to LLRW wastes from
existing facilities: these wastes typically consist of contaminated protective shoe covers and
clothing, wiping rags, mops, filters, equipment and tools, and other contaminated objects
depending on the nuclear application (NRC 2017-TN6545). The radioactivity can range from just
above the background levels found in nature to very highly radioactive. LLRW that contains
radionuclides that have shorter decay times can be stored onsite by licensees until it can be
released in accordance with 10 CFR Part 20, Subpart K (TN283). LLRW that contains
radionuclides that have longer decay times can be stored onsite until material inventory
amounts are large enough for shipment to a low-level waste disposal site. Applicable
regulations from the NRC (10 CFR Part 71-TN301, “Packaging and Transportation of
Radioactive Material”) and/or the U.S. Department of Transportation (49 CFR-TN7054) must be
used when offering licensed material for transport.

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The NRC requires that all licensees implement measures to minimize, to the extent practicable,
the generation of radioactive waste (10 CFR 20.1406 [TN283]). Additionally, the new reactor
licensee could do the following:

• Build additional temporary radiological storage facilities on the site.

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• Enter into an agreement with a third-party contractor to process, store, own, and ultimately
dispose of LLRW from the new reactor site.

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The Low-Level Radioactive Waste Policy Amendments Act of 1985 (Public Law 99-240;
TN6517)15 gave States the responsibility for disposal of the LLRW generated at commercial
facilities within their states. States are encouraged to enter into compacts that allow them to
dispose of the waste at a common disposal facility shared by multiple states. Depending on the
location of the new reactor site, the reactor licensee could contract with one or more licensed
LLRW disposal sites. There are currently four operating disposal facilities in the United States
that are licensed to accept LLRW from commercial facilities (including nuclear power plants)
(NRC 2020-TN6516). They are located at Clive, Utah; Andrews County, Texas; Barnwell, South
Carolina; and near Richland, Washington. The EnergySolutions disposal facility at Clive, Utah,
is licensed by the State of Utah to accept Class A LLRW from all regions of the United States.
The Waste Control Specialists, LLC (WCS) site in Andrews County, Texas, is licensed to accept
Class A, B, and C LLRW from the Texas Compact generators (Texas and Vermont) and from
outside generators with permission from the Texas Compact. EnergySolutions Barnwell
Operations located near Barnwell, South Carolina, accepts waste from the Atlantic Compact
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The Low-Level Radioactive Waste Policy Amendments Act superseded, in its entirety, an earlier law, the Low-Level
Radioactive Waste Policy Act of 1980 (Public Law 96-573; TN6606).

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states (Connecticut, New Jersey, and South Carolina) and is licensed by the State of South
Carolina to dispose of Class A, B, and C LLRW. U.S. Ecology, located near Richland,
Washington, accepts LLRW from the Northwest and Rocky Mountain Compact states
(Washington, Alaska, Hawaii, Idaho, Montana, Oregon, Utah, Wyoming, Colorado, Nevada, and
New Mexico) and is licensed by the State of Washington to dispose of Class A, B, and C waste.
A new reactor licensee would likely have to choose one or a combination of these options.
Section 3.10.1.2 addresses the potential environmental impacts of using LLRW disposal
facilities. The NRC staff anticipates that a new reactor licensee would enter into an agreement
with one of the four above facilities or make alternative arrangements in accordance with
10 CFR Part 20 Subpart K (TN283).

3.10.1.1.2 High-Level Waste

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The only two types of high-level waste (HLW) generated at new reactors would be spent nuclear
fuel and, potentially, waste from fuel reprocessing (e.g., removal of fission products during
operation from liquid-fueled molten-salt reactors) (NRC 2020-TN6955). The regulations for the
storage of HLW are found in 10 CFR Part 72 (TN4884) and apply to the proper storage and
handling of spent nuclear fuel in an ISFSI. Section 3.14.2.6 provides more information about the
storage and disposal of spent nuclear fuel.

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New reactor designs may not require onsite spent nuclear fuel storage, for example, in cases
where the depleted core would be shipped offsite after a short period after shutdown (see
Section 3.14 for away-from-reactor impacts during continued storage).

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If spent nuclear fuel or any treated, reprocessed waste needs to be stored temporarily at a new
reactor facility, it would be stored either in a spent fuel pool or in non-water-based spent nuclear
fuel storage. After an appropriate holding period, it would be transferred to dry cask storage in
an at-reactor ISFSI under a general license or a stand-alone ISFSI under specific license.

3.10.1.1.3 Mixed Wastes

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Mixed waste, regulated under the RCRA (TN1281) and the Atomic Energy Act of 1954
(42 U.S.C. §§ 2011 et seq.; TN663), is waste that is both radioactive and hazardous (EPA 2019TN6956). These wastes are subject to dual regulation by the EPA or an authorized State for
their hazardous component, and by the NRC or an Agreement State for the radioactive
component. Nuclear power plants generate small quantities of mixed waste, typically accounting
for less than 3 percent by volume of the annual LLRW (NRC 1996-TN288). The NRC staff
assumes that new reactors would be similar small-quantity generators and generate mixed
wastes similar to those wastes generated at currently operating nuclear power plants. If any
new reactor would generate more mixed wastes than is assumed in this GEIS, the associated
impacts would need to be assessed in the site-specific environmental report developed for the
licensing of that facility.

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The types of mixed wastes generated at nuclear power plants include organics (e.g., liquid
scintillation fluids, waste oils, halogenated organics), metals (e.g., lead, mercury, chromium, and
cadmium), solvents, paints, cutting fluids, cleaning and refrigeration effluents, and corrosives
from acids. The quantity of mixed waste generated varies considerably from plant to plant (NRC
1996-TN288). The EIS for the Fermi Unit 3 COL (NUREG-2105; NRC 2013-TN6436) states that
0.416 m3/yr (0.544 yd3/yr) of mixed waste would be generated during operation. Overall, the
quantities generated during operations are generally relatively small, but because of the added
complexity of dual regulation, it is more problematic for plant owners to manage and dispose of

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mixed wastes than the other types of wastes. Similar to hazardous waste, mixed waste is
generally accumulated onsite in designated areas as authorized under RCRA, then shipped
offsite for treatment as appropriate and for disposal. The only disposal facilities that are
authorized to receive mixed LLRW for disposal at present are the EnergySolutions and the
WCS facilities (NRC 2024-TN10161).

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The NRC staff assumes that a new reactor licensee would manage mixed waste in accordance
with appropriate regulations and BMPs. In addition, the NRC staff assumes that a licensee for a
new reactor would produce waste in quantities that would allow classification as a small-quantity
generator of hazardous waste, based on the design features of new reactors and the fact that
other large LWRs can meet the classification.

3.10.1.2

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The NRC staff identified three environmental issues for analysis of waste management
associated with a new reactor:

Radiological Waste Impacts

• LLRW

• onsite spent nuclear fuel management

• mixed waste.

3.10.1.2.1 Low-Level Radioactive Waste

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The NRC staff assumes the new reactor site would have sufficient storage for LLRW. The NRC
dose limitations (10 CFR Part 20-TN283) would apply for both public and occupational radiation
exposure for any onsite facilities (see Section 3.8.1 of this GEIS). The radiological
environmental monitoring programs around nuclear power plants that operate such LLRW
storage facilities show that the increase in radiation dose at the site boundary is not significant
(NRC 2024-TN10161). The NRC staff has concluded that doses to members of the public from
the operation of onsite LLRW storage facilities would have a minimal impact.

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In addition, the NRC staff assessed in the License Renewal GEIS the impacts of onsite LLRW
storage at currently operating nuclear power plants and concluded that the radiation doses to
offsite individuals from onsite LLRW storage are not significant (NRC 2024-TN10161). The
expected types of LLRW generated by new reactors would be very similar to those generated
by currently operating nuclear power plants (i.e., LLRW in the form of contaminated protective
shoe covers and clothing, wiping rags, mops, filters, equipment and tools, etc.), although the
amount is expected to be less because some new reactor designs involve sealed reactor
systems (e.g., microreactors) and other designs could have fewer operational maintenance
activities, which include only typical sources of LLRW (listed above). The building and operation
activities for these onsite LLRW storage facilities for a new reactor would be similar to those of
LLRW storage facilities for existing nuclear power plants. However, the magnitude of the impact
is expected to be less for many designs, based on factors such as lower power levels, less
complex reactor systems, remote maintenance operations, and reduced maintenance activities
generating reduced volumes of LLRW.

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For the shipment of LLRW offsite to a licensed disposal site (as discussed in
Section 3.10.1.1.1), the NRC staff assumes that the quantities shipped and associated impacts
would be bounded by the impact assessment provided in Section 4.11.1.1 and by the data in
Tables 3.11-1 and 3.11-2 of the License Renewal GEIS (NRC 2024-TN10161) related to the
volume and activity of LLRW shipped offsite in 2021 for 11 power plant sites. This information is
incorporated here by reference.

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The NRC staff concluded that there should be no significant issues or environmental impacts
associated with onsite storage of LLRW generated by nuclear power plants, including new
reactors. Onsite storage facilities would be used until the wastes could be safely shipped to
licensed LLRW disposal facilities as previously discussed. The NRC staff considers impacts of
LLRW management to be SMALL and a Category 1 issue, because of expected compliance
with regulations and policies governing radiological waste management. The staff relied on the
following PPE assumptions to reach this conclusion:

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• Applicants must meet the regulatory requirements of 10 CFR Part 20 (TN283) (e.g., 20.1406
and Subpart K), 10 CFR Part 61 (TN252), 10 CFR Part 71 (TN301), and 10 CFR Part 72
(TN4884).

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• Quantities of LLRW generated at many new reactors would be less than the quantities of
LLRW generated at existing nuclear power plants, which generate an average of 21,200 ft3
(600 m3) and 2,000 Ci (7.4 × 1013 Bq) per year for boiling water reactors and half that
amount for pressurized water reactors (NRC 2024-TN10161).

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As discussed above, in previous assessments the NRC staff concluded that there would be no
significant environmental impacts associated with onsite storage of LLRW generated by nuclear
power plants, and this conclusion can be applied to new reactors addressed in this GEIS.
Onsite storage facilities would likely be used at new reactors until these wastes could be safely
shipped to licensed LLRW disposal facilities as previously discussed. Currently operating LLRW
disposal facilities have adequate capacity to accommodate the increased demand from new
reactors. The NRC staff considers impacts of LLRW management to be SMALL and a
Category 1 issue based on the information already available about LLRW management for
currently operating nuclear facilities and because of expected compliance with regulations and
policies governing radiological waste management.

3.10.1.2.2 Onsite Spent Nuclear Fuel and High-Level Waste Management

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Because a new reactor is assumed to generate less spent nuclear fuel than currently operating
reactors in the United States (i.e., due to smaller cores and longer core lifetimes), the NRC staff
assumes that the impacts of onsite spent nuclear fuel management at new reactor facilities
would be bounded by the impacts of spent nuclear fuel storage at current nuclear power plants.
The environmental impacts of storage are assessed for current nuclear power plants in the
context of operating license renewal in Section 4.11.1.2 of the License Renewal GEIS (NRC
2024-TN10161). Current and potential environmental impacts from spent nuclear fuel storage
onsite at the reactor sites are well understood and the environmental impacts during the license
renewal term were found to be small (NRC 2024-TN10161). Offsite spent nuclear fuel storage
and disposal impacts are addressed in Section 3.14.2.6 of this GEIS. During the operational
lifetime of the new reactor, appropriate handling and storage of spent nuclear fuel must be
performed in accordance with NRC regulations (e.g., 10 CFR Part 72-TN4884). While liquid-fuel
molten-salt reactors (MSRs) could process the molten salt to remove fission products and other
radionuclides, the resulting high-level and TRU waste must be handled and stored in
accordance with NRC regulations (see Section 3.14.2.5 for discussion of reprocessing).

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Assuming an appropriate decay time, new reactor management of spent nuclear fuel would be
similar to current reactor sites and use similar ISFSIs, with a currently approved cask design or
a specially designed spent nuclear fuel storage facility or dry cask storage system. The NRC
staff assumes that radiological impacts would be within regulatory limits; thus, the environmental
impacts of onsite storage during operations would be SMALL. The NRC staff’s overall
conclusion about onsite management of spent nuclear fuel, high-level waste, and TRU waste
during the licensed lifetime of operations for new reactors is that the environmental impacts
would be minor. This is a Category 1 issue. The staff relied on the following PPE assumptions to
reach this conclusion:
• Compliance with 10 CFR Part 72 (TN4884).

3.10.1.2.3 Mixed Waste

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New reactors could also be expected to generate small quantities of mixed waste. The waste at
the new reactor site would either be treated onsite or sent offsite for treatment followed by
disposal at a permitted landfill licensed to accept mixed waste. The comprehensive regulatory
controls and the facilities and procedures that are in place at nuclear power plants ensure that
the mixed waste is properly handled and stored. The NRC staff assumes that the radioactive
dose and exposure to toxic materials from mixed waste should have a small contribution to
LLRW impacts based on existing impacts at current LWRs, as was assessed in the License
Renewal GEIS (NRC 2024-TN10161 [see Section 4.11.1.4, Mixed Waste Storage and
Disposal]). Therefore, the radiological and nonradiological environmental impacts from the longterm disposal of mixed waste for any individual new reactor is considered SMALL. This is a
Category 1 issue. The staff relied on the following PPE assumptions to reach this conclusion:

• RCRA Small Quantity Generator (EPA 2020-TN6590) for Mixed Waste.

3.10.2 Nonradiological Waste Management

3.10.2.1

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Baseline conditions influencing nonradiological waste impacts associated with building and
operation of a new reactor include consideration of waste forms, classifications, and exposure
pathways. Nonradiological waste can exist in a gaseous, liquid, or solid form. Nonradiological
waste can further be classified as hazardous or nonhazardous. When hazardous waste is
combined with radiological waste it is referred to as mixed waste. Mixed waste is addressed in
Section 3.10.1.2.3. Exposure pathways to nonradiological waste can be either through
inhalation, ingestion, or absorption. See Section 3.3.1 for information regarding air quality,
Section 3.4.1 for water resources, Section 3.8.1 for public and occupational health information,
Section 3.11.1 for postulated accidents, and Section 3.15.1 for transportation of fuel and waste.

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The assumption of the PPE/SPE developed for this GEIS is that the licensee must meet all
applicable permit conditions and regulations, and perform all appropriate BMPs related to solid,
liquid, and gaseous waste. The NRC staff also assumes that licensees would implement
mitigation measures, such as recycling, along with using the least hazardous substance in its
operations, as appropriate.

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Hazardous waste is defined by the EPA in 40 CFR Part 261 (TN5092). Hazardous wastes may
be wastes that are specifically listed as known hazardous wastes or wastes that have one or
more characteristics of ignitability, corrosivity, reactivity, or toxicity. Types of hazardous wastes
common to new reactors or electric power generation facilities include waste paints, lab packs,

Baseline Conditions and PPE/SPE Values

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and solvents. Per the License Renewal GEIS (NRC 2024-TN10161), most LWRs accumulate
their hazardous waste onsite as authorized under RCRA (42 U.S.C. §§ 6901 et seq.; TN1281)
and transport it to treatment facilities for processing (NRC 2024-TN10161). The remaining
residues are sent to permanent disposal facilities. A class of hazardous waste called universal
waste is handled differently than hazardous waste, and includes batteries, pesticides,
mercury-containing equipment, light bulbs, and aerosol cans. Federal universal waste
regulations can be found in 40 CFR Part 273 (TN6587). All aspects of hazardous waste, such
as generation, treatment, transportation, and disposal, are regulated by the EPA or by States
under agreements with the EPA per the regulations set forth under RCRA.

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RCRA also defines categories of hazardous waste generators (EPA 2020-TN6590). These
types include large-quantity generators, small-quantity generators, and very small-quantity
generators. Very small-quantity hazardous waste generators create 100 kg or less per month of
hazardous waste or 1 kg or less per month of acutely hazardous waste. Small-quantity
hazardous waste generators create more than 100 kg but less than 1,000 kg of hazardous
waste per month. Large-quantity hazardous waste generators create 1,000 kg per month or
more of hazardous waste or more than 1 kg per month of acutely hazardous waste. The ESP
application for the Clinch River small modular reactor expected the facility to qualify as a smallquantity generator (TVA 2019-TN6589). The ESPs application for the Public Service Enterprise
Group stated that it maintains the program required of a small-quantity generator (PSEG 2014TN3452). The assumption of the PPE/SPE developed for this GEIS is that the proposed plant
would conform to RCRA regulations.

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Nonhazardous waste is waste that is not contaminated with either radionuclides or hazardous
chemicals. These wastes include office trash, paper, wood, oils not mixed with hazardous waste
or radiological waste, and sewage. Solid wastes, defined as nonhazardous by 40 CFR Part 261
(TN5092) are collected and disposed of in a landfill. Sanitary wastes defined as nonhazardous
by 40 CFR Part 261 are treated either at an onsite sewage treatment plant (as in the case of
many large-scale industrial facilities), discharged directly to a municipal sewage system for
treatment, or discharged to onsite septic tanks. The assumptions of the PPE/SPE developed for
this GEIS is that the quantity of water discharged to a municipal system would be within the
receiving system’s capacity, as noted in Appendix G.

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Large LWRs have nonradioactive waste management systems in place that manage both
hazardous and nonhazardous wastes. For example, boiler blowdown, water treatment wastes,
boiler metal cleaning wastes, laboratory and sampling wastes, floor and yard drains, and
stormwater runoff are all managed by these systems and are regulated by an NPDES permit,
with the exception of wastes in solid form (NRC 2024-TN10161). See Section 3.4 for further
discussion of water resources. The NRC staff assumes that new reactors would have some of
the same systems as a large LWR, although new reactor designs may vary.

3.10.2.2

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The NRC has assessed nonradiological waste impacts arising from the existing operating fleet
during license renewal assessments and from proposed new reactors as part of the COL and
ESP process under 10 CFR Part 52 (TN251). Nonradiological waste impacts resulting from the
refurbishment and operation of typical large LWRs in the existing U.S. fleet are evaluated in the
License Renewal GEIS (NRC 2024-TN10161). Nonradiological waste impacts from building and
operating LWRs have been evaluated in several EISs and the impacts were found to be
SMALL. Impacts of nonradiological waste from building and operating a new reactor would
generally be bounded by the impacts associated with large LWRs. See Section 3.3.2 for

Nonradiological Waste Impacts

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impacts on air quality, Section 3.4.2 for impacts on water resources, Section 3.8.2 for impacts
on public and occupational health impacts, Section 3.11.2 for impacts of postulated accidents,
and Section 3.15.2 for impacts of the transportation of fuel and waste.

3.10.2.2.1 Environmental Consequences of Construction

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The primary nonradiological waste impacts of building a new reactor would be those associated
with building activities. Impacts would include the generation, handling, and disposal of waste
and would be bounded by those of any large-scale construction project. Building waste impacts
would depend on whether the new reactor was built at a greenfield (undeveloped land),
brownfield (previously developed land available for redevelopment), or currently industrialized
site. Potential types of nonradioactive wastes expected from building a new reactor would
include construction debris, spoils, stormwater runoffs, municipal and sanitary waste, dust,
hazardous waste from construction equipment maintenance (e.g., oils and solvents), and air
emissions. Impacts are categorized into one of three waste types: solid, liquid, and gaseous.

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Building a new reactor could result in solid waste materials such as construction debris from
excavation, land clearing, and municipal waste. Debris could either be shipped to a local
construction debris landfill or the licensee could construct and operate its own onsite landfill. For
example, the Tennessee Valley Authority proposed to construct and operate an onsite landfill in
its application for an ESP (TVA 2019-TN5854). The NRC staff assumes municipal and
hazardous solid waste would be handled and shipped to the appropriate licensed disposal
facility in accordance with applicable regulations. If a licensee were to construct an onsite
landfill, those impacts would be considered in a project-specific EIS.

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Building activities related to building a new reactor could result in liquid waste, such as
stormwater runoffs. Surface water and groundwater have the potential to be affected by building
activities. The NRC staff assumes the applicant for a new reactor would obtain an NPDES
permit for stormwater discharges and maintain a Stormwater Pollution Prevention Plan to
minimize potential impacts. The NRC staff also assumes that an erosion and sediment control
plan would be implemented as part of the NPDES permit. In addition, the NRC staff assumes
sanitary wastes would be handled and shipped to the appropriate licensed disposal facility, such
as a local municipal sanitary waste facility. Mitigation for stormwater runoff could include
creation of berms around temporary spoils areas, trenching, drainpipes, culverts, and swales to
direct runoff to retention ponds. Dewatering at the construction site could be expected for the
nuclear island area if the design of the new reactor calls for subsurface installation of major
components. Mitigation could include use of horizontal drains to direct water to sumps, grouting
to prevent inflow of groundwater, and pumping water from sumps to construction-stormwater
management systems. Impacts of dewatering are discussed in Section 3.4.

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In addition, building activities could result in gaseous waste. Examples of gaseous waste
include construction equipment and vehicle emissions and fugitive dust from earthmoving
activities. Air permits are required for construction activities. In addition, the NRC staff assumes
licensees would use BMPs, such as stabilizing construction roads and spoil piles, covering haul
trucks, watering unpaved construction roads, and maintaining equipment in proper working
order, as discussed in Section 3.3.

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The staff has determined that nonradiological waste impacts during construction of a new
reactor are a Category 1 issue. The staff concluded that as long as the applicable PPE and SPE
values and assumptions are met, the nonradiological waste impacts from building a new reactor
can be generically determined to be SMALL. The staff relied on the following PPE values and
assumptions to reach this conclusion:

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• The applicant must meet all the applicable permit conditions, regulations, and BMPs related
to solid, liquid, and gaseous waste management.

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• For hazardous waste generation, applicants must meet conformity with hazardous waste
quantity generation levels in accordance with RCRA.

• For sanitary waste, applicants must dispose of sanitary waste in a permitted process.

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• For mitigation measures, the applicant would perform mitigation measures to the extent
practicable, such as recycling, process improvements, or the use of a less hazardous
substance.

3.10.2.2.2 Environmental Consequences of Operation

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The NRC staff assumes the nonradiological waste impacts of operating a new reactor would be
smaller than those experienced during building and would depend on the design of the new
reactor. Impacts would result from the generation, handling, and disposal of nonradiological
waste. Such waste can be classified as either hazardous or nonhazardous and found in solid,
liquid, or gaseous forms. Depending on the new reactor design, some waste streams may be
reduced or eliminated relative to a large LWR. For instance, reactors moderated by substances
other than water may not have a significant water footprint.

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New reactor operational activities could result in solid waste materials such as office waste,
cardboard, wood, metal, sewage treatment sludge, and resins. The NRC staff assumes
municipal (office trash) and hazardous solid waste would be handled and shipped to the
appropriate licensed disposal facility in accordance with the applicable regulations, while
cardboard, paper, wood pallets, and metal would be recycled, as appropriate. BMPs regarding
solid waste for a new reactor would be similar to those already in use for large LWRs.

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The operation of a new reactor could result in liquid waste materials such as chemicals,
biocides (for control of algae), and stormwater runoff. These discharges would be from cooling
or other operations of the reactor and would be managed in accordance with Federal, State,
local or tribal regulations. Sanitary waste would either be discharged to a permitted municipal
sanitary system or treated in an onsite sanitary system. The NRC staff assumes the licensee
would comply with all applicable permits and use BMPs to control liquid waste materials.

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Gaseous waste materials would come from operation of diesel generators, fossil-fuel boilers,
and from the coolant system (i.e., if the new reactor was a gas-cooled reactor). Section 3.3
contains further information about air quality impacts. Gaseous wastes include CO, NOx, carbon
dioxide (CO2), methane (CH4), N2O, PM, and VOCs for diesel-, natural-gas-, and oil-fired units.
Gaseous waste materials associated with a new reactor would be managed in accordance with
Federal, State, local, or tribal regulations. In addition, the NRC staff assumes the licensee would
comply with all applicable permits and use BMPs for these wastes.

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Mitigation for waste management could include recycling, improving an operational process, or
using a less hazardous chemical, such as using aqueous ammonium versus anhydrous
ammonia.

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The staff has determined that nonradiological waste impacts during operation of a new reactor
are a Category 1 issue. The staff concluded that as long as the applicable PPE and SPE values
and assumptions are met, the nonradiological public and occupational health impact from
operating a new reactor can be generically determined to be SMALL. The staff relied on the
following PPE values and assumptions to reach this conclusion:

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• The applicant must meet all the applicable permit conditions, regulations, and BMPs related
to solid, liquid, and gaseous waste management.

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• For hazardous waste generation, applicants must meet conformity with hazardous waste
quantity generation levels in accordance with RCRA.

• For sanitary waste, applicants must dispose of sanitary waste in a permitted process.

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• For mitigation measures, the applicant would perform mitigation measures to the extent
practicable, such as recycling, process improvements, or the use of a less hazardous
substance.

3.11 Postulated Accidents

3.11.1 Baseline Conditions and PPE/SPE Values and Assumptions

3.11.1.1

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Radiological effects from a postulated accident from such nuclear facilities are considered for
their impacts with respect to the following regulatory requirements:

Design Basis Accidents Involving Radiological Releases16

• 10 CFR 50.34(a)(1) (TN249), “Contents of applications; technical information.”

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• 10 CFR 52.79(a)(1)(A) (TN251), “Contents of applications; technical information in final
safety analysis report.”

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Based on the regulations, whether it is a non-LWR or LWR design, the new reactor design basis
accident (DBA) analysis must satisfy the following:

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• For the exclusion area boundary, the maximum total effective dose equivalent (TEDE) for
any 2-hour period during the radioactivity release should be calculated.

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• For the low-population zone, the TEDE should be calculated for the duration of the accident
release (i.e., 30 days, or other duration as justified).

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• Comparison of the DBA doses with the dose criteria given in regulations related to the
application (e.g., 10 CFR 50.34(a)(1) [TN249], 10 CFR 52.17(a)(1) and 10 CFR 52.79(a)(1)
[10 CFR Part 52-TN251]), standard review plans (SRPs) (e.g., SRP criteria, Table 1 in SRP
Section 15.0.3 of NUREG-0800 [NRC 2007/2019-TN6221]), and RGs, (e.g., RG 1.183
[NRC 2000-TN517]), as applicable.

3.11.1.2

Accidents Involving Releases of Hazardous Chemicals

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The effects of hazardous chemical releases from nearby facilities have traditionally been
reviewed as part of safety reviews for their effects on control room habitability (see
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For the purposes of this GEIS, “Design Basis Accidents” are related to a spectrum of accidents that will be
evaluated for satisfying siting requirements (e.g., 10 CFR Part 100) and the safety analysis requirements (e.g., 10
CFR Part 50, Part 52) or the applicable NRC safety and siting regulations in place at the time the application is
docketed).

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NUREG-0800, Section 2.2.1–2.2.2, Identification of Potential Hazards in Site Vicinity, and
Section 6.4, Control Room Habitability System; NRC 2007-TN613).

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EPA also regulates hazardous chemicals. For example, the Risk Management Plan Rule
(40 CFR Part 68-TN5494) requires facilities that produce, process, or store extremely
hazardous substances must identify hazards associated with an accidental release, design and
maintain a safe facility, prepare a Risk Management Plan (RMP) and minimize consequences of
accidental releases that occur. Facilities holding more than a threshold quantity (TQ) of a
regulated substance in a process are required to comply with 40 CFR Part 68 (TN5494). As
provided in 40 CFR 68.130, Tables 1, 2, 3, and 4 list the regulated substances and their TQs.

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The Emergency Planning and Community Right-to-Know Act (EPCRA) requires that if an
extremely hazardous substance (EHS) in quantities at or above the Threshold Planning
Quantity (TPQ) is present at a facility, then certain emergency planning activities must be
conducted. For example, Local Emergency Planning Committees (LEPCs) must develop
emergency response plans and facility owner or operator must notify the State Emergency
Response Commission or Tribal Emergency Response Commission and their LEPC if any of
the EHS is present at the facility or above its TPQ. The EHSs and their TPQs are listed in
40 CFR Part 355, Appendices A and B (40 CFR Part 355-TN5493).

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Because of the potential for the use of hazardous chemicals in the operation of a new reactor,
there is also the potential for releases of hazardous chemicals as a result of postulated
accidents. In developing the PPE values and assumptions pertaining to accidents involving
releases of hazardous chemicals, the staff assumed that if a regulated substance or EHS is
present at a new reactor facility in quantities less than the requirement for establishing an RMP
and offsite emergency planning, then the consequences of releases of these hazardous
chemicals would be small. To establish the PPE, the staff is applying the list of regulated
substances and TQs contained in 40 CFR 68.130, and the list of EHSs and TPQs contained in
40 CFR Part 355, Appendices A and B (TN5493). The PPE assumptions are as follows:

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• new reactor inventory of a regulated substance is less than its TQ. TQs are found in 40 CFR
68.130, Tables 1, 2, 3, and 4 (TN5494); and

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• new reactor inventory of an EHS is less than its TPQ. TPQs are found in 40 CFR Part 355,
Appendices A and B (TN5493).

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If the PPE above is exceeded and a new reactor facility has the potential to release hazardous
chemicals from licensed operations, the applicant should provide an analysis in the ER that
estimates the consequences to members of the public in the event of such a release. Generally
available information or protective emergency guidelines can be useful when characterizing the
consequences (e.g., Acute Exposure Guideline Levels (AEGLs), 17 Emergency Response
Planning Guidelines,18 Temporary Emergency Exposure Limits,19 or Protective Action Criteria

AEGLs are guidelines designed to help responders deal with emergencies involving chemical spills or other
catastrophic events during which members of the general public are exposed to a hazardous airborne chemical
(NOAA ORR 2019-TN7023).
18
Emergency Response Planning Guidelines are guidelines designed to anticipate the health effects from exposure
to certain airborne chemical concentrations (NOAA ORR 2019-TN7024).
19
Temporary Emergency Exposure Limits are guidelines designed to predict the response of members of the general
public to different concentrations of a chemical during an emergency response incident (NOAA ORR 2020-TN7025).

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for Chemicals.20 Relevant analysis prepared for compliance with other State or Federal
regulations (e.g., an RMP submitted under 40 CFR Part 68 [TN5494]) should be provided as
applicable.

3.11.1.3

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7
8

The Commission provided direction to the staff for the environmental assessment of severe
accidents in their policy statement entitled “Nuclear Power Plant Accident Considerations Under
the National Environmental Policy Act of 1969,” which includes the following statements
(45 FR 40101-TN4270):

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It is the position of the Commission that its Environmental Impact Statements,
pursuant to Section 102(c)(i) of the National Environmental Policy Act of 1969
[42 U.S.C. §§ 4321 et seq.; TN661], shall include a reasoned consideration of the
environmental risks (impacts) attributable to accidents at the particular facility or
facilities within the scope of each such statement. In the analysis and discussion
of such risks, approximately equal attention shall be given to the probability of
occurrence of releases and to the probability of occurrence of the environmental
consequences of those releases. Releases refer to radiation and/or radioactive
materials entering environmental exposure pathways, including air, water, and
groundwater.

Severe Accidents

and

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The environmental consequences of releases whose probability of occurrence
has been estimated shall also be discussed in probabilistic terms. Such
consequences shall be characterized in terms of potential radiological exposures
to individuals, to population groups, and, where applicable, to biota. Health and
safety risks that may be associated with exposures to people shall be discussed
in a manner that fairly reflects the current state of knowledge regarding such
risks. Socioeconomic impacts that might be associated with emergency
measures during or following an accident should also be discussed. The
environmental risk of accidents should also be compared to and contrasted with
radiological risks associated with normal and anticipated operational releases.

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The technical rationale for evaluation of the applicant’s severe accident analysis is discussed in
Section 7.2 of the Environmental Standard Review Plan (NRC 2007-TN5141) as follows:

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The Commission has determined that the evaluation of events or accident
sequences that lead to releases shall include, but not be limited to, those events
or sequences that can reasonably be expected to occur. It has also stated that
the environmental consequences of releases whose probability of occurrence
has been estimated shall be discussed in probability terms. The consequences of
the accidents that can reasonably be expected to occur are expressed in terms
of potential exposure to individuals; the consequences of severe accidents
referred to as probabilistic accidents in the policy statements [50 FR 32138TN4519, 51 FR 30028-TN594] are characterized in terms of exposure to
population groups.
20

The Protective Action Criteria for Chemicals data set is a hierarchy-based system of the three common public
exposure guideline systems (AEGLs, ERPGs, and Temporary Emergency Exposure Limits) (NOAA ORR 2020TN7026).

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Releases refer to radiation or radioactive materials or both entering
environmental exposure pathways, including air, water, and groundwater. Inplant accident sequences that can lead to a spectrum of releases shall be
discussed and shall include sequences that can result in inadequate cooling of
reactor fuel and melting of the reactor core. The events arising from causes
external to the plant that are considered possible contributors to the risk
associated with the plant should be discussed. Socioeconomic impacts
associated with emergency measures during or following an accident should also
be discussed, and the environmental risks compared to and contrasted with
radiological risks should be associated with normal and anticipated operational
releases.

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15

The Commission also takes the position that detailed quantitative considerations
that form the basis of probabilistic estimates of releases do not need to be
incorporated into the EIS, but may be referenced, including references to safety
evaluation reports.

3.11.1.4

Severe Accident Mitigation Design Alternatives

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The purpose of the evaluation of severe accident mitigation alternatives (SAMAs) is to
determine whether there are severe accident mitigation design alternatives (SAMDAs),
procedural modifications, or training activities that can be justified to further reduce the risks of
severe accidents (NRC 2000-TN614). Because new reactors are not anticipated to have
established appropriate training and procedures to address severe accidents, this review will
only focus on SAMDAs.

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The current guidance for SAMAs is based on several documents, including NUREG/BR-0058,
Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission (NRC 2004TN670), and NUREG/BR-0184, Regulatory Analysis Technical Evaluation Handbook
(NRC 1997-TN676), with industry guidance for license renewals provided in Nuclear Energy
Institute (NEI) 05-01, Severe Accident Mitigation Alternatives (SAMA) Analysis, Guidance
Document (NEI 2005-TN1978). However, the expected probabilities for a new reactor severe
accident could be very low. In such a case, a simple SAMA screening could determine whether
a detailed SAMA evaluation is necessary, or that a potentially cost-beneficial SAMA does not
exist.

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The screening process should be based on the available risk information from the Final Safety
Analysis Report (FSAR)/Preliminary Safety Analysis Report (PSAR) and apply selected cost
formulas from NUREG/BR-0184 (NRC 1997-TN676) as a first step rather than a last step, as
prescribed under current SAMA practices. The cost formulas for occupational exposure risk
cost, cleanup and decontamination risk cost, and replacement power risk cost are all
independent of offsite consequences and have input parameters that should be readily
available. If the resulting partial maximum benefit cost is clearly low enough that even the
largest hypothetical offsite population dose and offsite economic risks for the new reactor design
could not raise the maximum benefit to match or exceed the lowest possible implementation
cost for any design alternative, then there cannot be a potentially cost-beneficial SAMA.
However, if the screening cannot reach such a conclusion, then a detailed SAMA evaluation is
necessary using the abovementioned guidance documents.

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The current guidance referenced above uses core damage frequency (CDF) to express the
probability of severe accidents that have a potential effect on the environment, including in cost

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formulas. CDF is a value that is determined in LWR probabilistic risk assessments (PRAs).
However, such a parameter may not be available or applicable to non-LWR PRAs. For nonLWR SAMA screening and assessments, event or release category frequency could be used in
place of CDFs.

3.11.1.5

Acts of Terrorism

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Previous U.S. Courts of Appeals decisions addressed the circumstances under which the NRC
must assess the environmental impacts of potential acts of terrorism and sabotage. The U.S.
Court of Appeals for the Ninth Circuit held that the NRC could not categorically refuse to
consider the consequences of a terrorist attack in an analysis under NEPA. 21 The Commission
thereafter stated it would adhere to the Ninth Circuit’s decision by considering the potential
impacts of a terrorist attack in making licensing decisions for facilities located within the Ninth
Circuit’s jurisdiction but it would not consider terrorist attacks in licensing decisions outside of
that court’s jurisdiction.22

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The U.S. Court of Appeals for the Third Circuit disagreed with the Ninth Circuit’s analysis of
NEPA case law.23 Instead, as the Commission had originally held, the Third Circuit concluded
that the issuance of a facility license would not be the “proximate cause” of a terrorist attack on
the facility.24 Moreover, the Third Circuit noted that the License Renewal GEIS (NRC 1996TN288) had reviewed the possible impacts of a sabotage event, which is a form of terrorism.
The License Renewal GEIS found that the consequences of a sabotage event would be no
worse than those expected from an internally initiated severe accident. As a result, the Third
Circuit found that, even if the Commission were required to analyze the impacts of a terrorist
attack, the NRC could not have evaluated the risks more meaningfully than it had already done
for internally initiated severe accidents.25

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These court decisions related to NEPA evaluations of terrorist attacks and the NRC staff’s
subsequent evaluations to address them are discussed in Section E.3, Accident Risk and
Impact Assessment, of Appendix E, Environmental Impact of Postulated Accidents, to the
License Renewal GEIS (NRC 2024-TN10161), and in Section 4.19, Potential Acts of Sabotage
or Terrorism, of NUREG-2157 (NRC 2014-TN4117), which are incorporated herein by
reference.

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As a result of these court decisions, the NEPA evaluation of an application for a new reactor to
be located at a site within the Ninth Circuit’s jurisdiction would need to address acts of terrorism.
For sites not within the jurisdiction of the Ninth Circuit, the NEPA evaluation would not address
acts of terrorism.

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As described in Appendix E of the License Renewal GEIS (NRC 2024-TN10161) and in
Section 4.19 of NUREG-2157 (NRC 2014-TN4117), the NRC will continue to address facility
physical security measures, including the prevention of and response to terrorist attacks,
through its ongoing regulatory and inspection processes. The NRC routinely assesses threats
21

San Luis Obispo Mothers for Peace v. NRC, 449 F.3d 1016 (9th Cir. 2006) (San Luis Obispo Peace v. Nuclear
Regulatory 2006-TN6959).
22
AmerGen Energy Co., LLC (Oyster Creek Nuclear Generating Station), CLI-07-8, 65 NRC 124, 126, 128
(NRC 2007-TN6957).
23
New Jersey Dept of Environmental Protection v. NRC, 561 F.3d 132 (3rd Cir. 2009) (NJ Dept. of Environmental
Protection v. NRC-TN6958).
24
Id., 561 F.3d at 140.
25
Id., 561 F.3d at 134, 136, 143-44.

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and other information provided by a variety of Federal agencies and sources. The NRC also
ensures that licensees meet appropriate security-level requirements. In this regard, the NRC
views facility physical security measures as a current, ongoing, and generic regulatory issue
that affects all nuclear facilities.

3.11.2 Postulated Accidents Impacts

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New reactor designs could be water-cooled large nuclear power plants (e.g., LWRs like the
AP1000), water-cooled small modular reactors (e.g., the NuScale SMR), or non-LWRs (e.g.,
high temperature gas, molten salt, and liquid sodium cooled nuclear power plants). The risks
from new reactor accidents may be limited. A major emphasis for the development of new
reactors is the minimization (i.e., a very low probability of an accident with an offsite radiological
or hazardous chemical release) or the elimination of radioactive or hazardous chemical releases
from accidents. Thus, the risks from new reactor accidents may be limited as presented in the
FSAR/PSAR of the new reactor application. However, the NRC staff cannot prejudge the level
of safety of a new reactor design a priori and, therefore, cannot rule out the need for a
postulated accident analysis in future license applications. To this end, this section also
incorporates the related guidance on postulated accidents and SAMAs from ISG-029,
“Environmental Considerations Associated with Micro-reactors” (NRC 2020-TN6710).

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To support the licensing of non-LWR designs, the staff developed and published RG 1.233,
Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to
Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and
Approvals for Non-Light-Water Reactors (NRC 2020-TN6441). The selection of licensing-basis
events; classification and special treatments of structures, systems, and components; and
assessment of defense-in-depth are fundamental to the safe design of non-LWRs. The
guidance provided in RG 1.233 may assist in the development of the new reactor applicant’s
accident analysis in the FSAR/PSAR. Regardless of whether or not a new reactor applicant
chooses to conform to RG 1.233, the applicant is required to provide an evaluation of events
including accident analyses, and for Part 52 applicants, a description and the results of the
project-specific probabilistic risk assessment in the FSAR/PSAR, which may be incorporated by
reference in the new reactor application’s ER in order to meet the PPE assumptions.

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This section addresses all design types of new reactors because the accident analysis is tied to
possible radioactive releases from postulated accidents and not for a specific type of new
reactor design.

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Based on the analyses in Section 3.11.1, the following five environmental issues related to
impacts from postulated accidents associated with a new reactor are discussed:

• design basis accidents involving radiological releases

• design basis accidents involving releases of hazardous chemicals

• severe accidents

• severe accident mitigation design alternatives

• acts of terrorism.

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3.11.2.1

Design Basis Accidents Involving Radiological Releases

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The environmental guidance for LWR DBA evaluations is provided in the current versions of
RG 4.2 (NRC 2024-TN7081) and Section 7.1 of NUREG-1555 (NRC 2013-TN3547). Prior LWR
DBA environmental evaluations were slightly different than the DBA analysis considered in the
safety reviews. Specifically, the environmental review of DBAs was based on applying
dispersion coefficients based on 50th percentile weather data (i.e., “realistic” weather
conditions) versus the 95th percentile weather data applied in the applicant’s DBA analysis in
Chapter 15 of the FSAR/PSAR. All other factors, such as accident categories and timeframes,
were the same for the two assessments. At the conclusion of the staff’s safety review, the
applicant’s DBA analysis would have to demonstrate to the staff that no regulatory limits were
exceeded, in part, for the NRC to issue the license. This also meant that 50th percentile weather
conditions used in the environmental DBA evaluation would also meet the same regulatory
limits, resulting in an environmental finding of SMALL. However, given that the safety evaluation
must reach a safety determination for DBAs for a license to be issued, it is reasonable to
conclude that the staff can also reach an environmental finding of SMALL (i.e., by meeting
regulatory requirements for safety) by relying on the DBA analysis in the applicant’s
FSAR/PSAR. Therefore, in future new reactor applications, the staff should be able to
incorporate by reference into the environmental evaluation the DBA analysis from the
FSAR/PSAR and the staff’s safety evaluation of DBAs.

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23

DBAs involving radiological releases are a Category 1 issue. The FSAR/PSAR must
demonstrate that the reactor falls within the regulatory limits discussed in Section 3.11.1; with
incorporation by reference to the ER, the PPE values would be met, and the impacts would be
SMALL. The staff relied on the following PPE assumptions to reach this conclusion:

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• For the exclusion area boundary, the maximum TEDE for any 2-hour period during the
radioactivity release should be calculated.

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• For the low-population zone, the TEDE should be calculated for the duration of the accident
release (i.e., 30 days, or other duration as justified).

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The above calculations would compare the DBA doses with the dose criteria given in
regulations related to the application (e.g., 10 CFR 50.34(a)(1) [TN249], 10 CFR 52.17(a)(1)
and 10 CFR 52.79(a)(1) [10 CFR Part 52-TN251]), SRPs (e.g., SRP criteria, Table 1 in SRP
Section 15.0.3 of NUREG-0800 [NRC 2007/2019-TN6221]), and RGs, (e.g., RG 1.183
[NRC 2000-TN517]), as applicable.

3.11.2.2

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Accidents involving releases of hazardous chemicals are a Category 1 issue. The applicant can
rely on the on the generic analysis in this GEIS if the new reactor inventories of regulated
substances and EHSs are less than their TQs and TPQs, respectively, and the impacts would
be SMALL. The staff relied on the following PPE assumptions to reach this conclusion:

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• new reactor inventory of a regulated substance is less than its TQ. TQs are found in 40 CFR
68.130, Tables 1, 2, 3, and 4 (TN5494)

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• new reactor inventory of an EHS is less than its TPQ. TPQs are found in 40 CFR Part 355,
Appendices A and B (TN5493)

Accidents Involving Releases of Hazardous Chemicals

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3.11.2.3

Severe Accidents

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Severe accidents are a Category 2 issue. Based on the analysis in the FSAR/PSAR regarding
severe accidents and PRAs, if a new reactor design has severe accident progressions that
involve radiological or hazardous chemical releases, then an environmental risk evaluation must
be performed.

3.11.2.4

Severe Accident Mitigation Design Alternatives

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It is expected that for severe accidents, although a Category 2 issue, the probabilistic risk
assessment provided in the safety analysis would have CDFs that would likely be substantially
less than the CDFs associated with the current reactor fleet. For non-LWR SAMA screening and
assessments, event or release category frequency could be used in place of CDFs. A cost
screening could determine that the maximum benefit of avoiding an accident is so small that a
SAMDA is not justified based on the minimum cost to design an appropriate SAMDA. This is a
Category 1 issue. The staff relied on the following PPE assumption to reach this conclusion:

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• If a cost-screening analysis determines that the maximum benefit for avoiding an accident is
so small that a SAMDA analysis is not justified based on a minimum cost to design an
appropriate SAMDA.

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This cost-screening process would be based on the available risk information derived from the
FSAR/PSAR and would apply the cost formulas from NUREG/BR-0058 (NRC 2004-TN670). If
SAMDAs are not screened out, the bounding assumption is not met and a project-specific
analysis is required. For example, the NuScale SMR 50 MWe single module has eight accident
release categories and seven out of eight accident release categories have release frequencies
of 2.4 × 10-9 per reactor-year or smaller (NuScale 2020-TN6811). The total estimated maximum
benefit of these seven low-probability release categories would be less than $100. It is unlikely
that a design mitigation alternative could be developed costing less than $100, so there is no
need to develop potential mitigation strategies.

3.11.2.5

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The NRC staff has determined that the environmental impacts of acts of terrorism and sabotage
only need to be addressed if a new reactor facility is subject to the jurisdiction of the U.S. Court
of Appeals for the Ninth Circuit. Because the environmental impacts of a facility subject to the
jurisdiction of this court cannot be determined without the consideration of project-specific
factors, the potential impacts of terrorism and sabotage for these facilities would require a
project-specific analysis. The necessary environmental evaluation would be performed based
on the design features that provide for physical protection of the new reactor from acts of
terrorism and sabotage. The impacts of acts of terrorism can be mitigated by complying with the
physical protection requirements under 10 CFR Part 73 (TN423), Physical Protection of Plants
and Materials, that provide reasonable assurance that the risk from sabotage is small. If a
facility is not subject to the jurisdiction of the U.S. Court of Appeals for the Ninth Circuit, then
this would be a Category 1 issue, since no other jurisdiction currently requires consideration of
the consequences of a terrorist attack in an analysis under NEPA.

Acts of Terrorism

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3.12 Socioeconomics

3.12.1 Baseline Conditions and PPE/SPE Values and Assumptions

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Baseline conditions influencing potential socioeconomic resources associated with the building
and operation of a new nuclear reactor include the economic and social service conditions
found currently in the vicinity of the site. The analysis will depend on information supplied by the
applicant. The applicable NRC guidance is Section 4.4 of RG 4.2, Revision 3, Preparation of
Environmental Reports for Nuclear Power Stations (NRC 2024-TN7081).

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The NRC’s Environmental Standard Review Plan (NRC 2000, 2007-TN614) suggests beginning
an analysis of the economic and demographic impacts of building and operating a nuclear
power reactor on an area within a 50-mile radius from the proposed plant. Depending on the
size and inherent safety features of new reactor designs, the radius of the analytical areas may
be reduced from that starting point. The demographic region is the geographic area within a
defined radius from the site for which demographic data are analyzed. Facility sites are located
within economic regions defined by the local labor market. The economic region for any facility
is based on the geographic area from which the facility will draw its workforce—typically a
grouping of counties surrounding the site. The economic region and the demographic region
may not be the same size or shape.

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The socioeconomic characteristics of potential sites for new reactors can vary widely, from
sparsely populated remote outposts to industrial facilities located in major metropolitan centers.
Thus, the staff adopted PPE/SPE values that are proportional metrics based on percentage
changes from baseline conditions, rather than absolute values.

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The PPE and SPE assume that most socioeconomic impacts are driven by changes in the local
workforce employed as a result of the proposed action. The in-migration of workers and their
families into an economic region for project building and operations, including outage activities,
imposes new demands on local infrastructure and community services. Previous new reactor
reviews also have shown that traffic impacts on local access routes may be greater than minor,
but not typically destabilizing. Beneficial impacts from increased tax revenues associated with
the increased assessed value of new reactor projects also tend to be noticeable within the
affected economic region or local taxing jurisdiction.

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Based on staff experience with new license applications for large LWRs, the NRC staff has
developed PPE/SPE values for each socioeconomic resource, which, if met, allow the staff to
reach a generic conclusion of beneficial or SMALL adverse impacts for that resource. The
principal assumption is that the project-related workforce together with associated families
would not result in a net increase in the population of the economic region that would be greater
than the planned growth for that region by local agencies over the same time period. Based on
workforce migration into the economic region, staff determined demand increases for
infrastructure (e.g., housing availability) and services (e.g., public schools) would not result in
specific thresholds being crossed. Similarly, the staff assumes that the LOS values for the
affected roadways would not change as a result of the added traffic pressure from the project
workforce traffic.

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In summary, the NRC staff provides the following PPE/SPE values (also summarized in
Appendix G):

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• The peak project-related in-migrating workforce including families does not exceed
established local planning and growth projections for infrastructure and service demands.

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• The housing vacancy rate in the affected economic region does not change by more than
5 percent, or at least 5 percent of the housing stock remains available.

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7

• The student:teacher ratios in the affected economic region’s classrooms do not exceed
locally mandated levels after including the school age children of the in-migrating worker
families.

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• The LOS determination for affected roadways does not change with the addition of the
commuting patterns of the building or operations workforce.

3.12.2 Socioeconomic Impacts

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Socioeconomic impacts from new reactors would occur during the building and operations
phases of the project. Impacts are linked to the size of the local workforce during site
preparation and the construction of safety-related facilities such as the nuclear island and nonsafety-related facilities such as cooling towers, administration buildings, parking lots,
switchyards, and any onsite and offsite pipelines, access roads, and transmission lines. Many
smaller new reactors may lack cooling towers, switchyards, or offsite pipelines or transmission
lines and may require a site of only a few acres. Larger new reactors may require some or all of
these support facilities and hence require larger sites. During operations, the principal
socioeconomic impacts would be from employment of the operations workforce and tax revenue
generated based on the assessed value of the project.

3.12.2.1

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26

Historically, the staff’s evaluation of socioeconomic impacts for building a new reactor primarily
focused on the in-migration of construction workers and their resulting impacts on local
community resources and infrastructure, and related economic impacts. These impacts can vary
considerably from site to site and between building and operations. The NRC staff identified four
socioeconomic issues for analysis of building a new reactor:

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30

• community services and infrastructure demands (specifically, housing and schools) altered
by construction workers and families migrating to the local economic region; traffic impacts
on local site access roadways and associated road networks; economic impacts such as
employment, economic output, and local labor income; and

• tax revenue impacts, such as sales and property taxes.

Socioeconomic Consequences of Construction

3.12.2.1.1 Community Services and Infrastructure

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To the degree that the size of the construction project requires the acquisition of workers from
outside the economic region, impacts related to worker migration would be expected. These
impacts occur as workers, including families, relocate temporarily or permanently to be closer to
the site. Impacts from local workers already residing within the economic region are assumed to
result in no net changes in service demands across the economic region, except as a part of
traffic impacts.

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The impacts of migration from outside the economic region are found by obtaining the
applicant’s estimate of the peak construction workforce anticipated to come from outside the
economic region. In recent new reactor reviews, the NRC staff evaluated the impacts from in-

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migrating workers and their families in the context of the local planning authority’s estimate of
population growth in the economic region. If the percentage of in-migrating construction workers
and their families relative to the total population of the economic region is less than the planned
rate of population growth in the economic region during the construction period, the reviewer
can determine the construction-related impact on housing, community services, and
infrastructure are within the planning authority’s management capabilities and, therefore, would
be minor.

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Recent new reactor reviews have shown that the principal community service affected by
building a new reactor is public school systems. As families migrate into the economic region,
local schools may observe increased class sizes at all levels. The PPE value of student:teacher
ratio is the principal metric used to assess classroom crowding impacts. The NRC staff
assumes that the impact of the new students would be minor as long as the addition of new
students from in-migrating worker’s families does not increase the student:teacher ratio beyond
the locally mandated level.

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22

Based on recent reviews of new reactors, the key infrastructure impact metric is housing
availability. This metric is assessed in terms of the proportion of the housing stock that is
available for residency. The staff assumes that the combination of available unoccupied
single-family dwellings and rental housing should remain greater than 5 percent in a healthy
housing market with relatively stable prices. The impact on housing would be minor, if the
addition of the in-migrating workers does not change the housing supply by 5 or more percent,
or if the available number of rental units in the economic region is 5 percent or more after
accounting for the rental units needed for the in-migrating construction workers.

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Experience reviewing new reactors has shown that other community service and infrastructure
impacts are generally minor. These include impacts on first-responder resources, public utilities
including potable water resources, health care resources, and other public services (e.g.,
community aid providers).

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The staff has determined that the public school system and housing availability are the most
likely places where impacts on community services and infrastructure can be observed during
building of a new reactor. The staff concludes that, as long as the applicable PPE and SPE
assumptions are met, the community services and infrastructure impacts from building a new
reactor can be generically determined to be SMALL and mitigation would not be warranted.
Therefore, the socioeconomic impacts from building a new reactor are a Category 1 issue. The
staff relied upon the following PPE assumptions to reach this determination:

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• Student:teacher ratios in the affected economic region do not exceed locally mandated
levels after including the school age children of the in-migrating worker families.

3.12.2.1.2 Transportation Systems and Traffic

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Facility building activities result in physical impacts on two aspects of local transportation
systems in the vicinity of the site: improvements and repairs to roads in anticipation of the
project, and traffic-related impacts (the decline in road service quality from construction worker
commutes). Transporting materials and equipment to the proposed site may require the
applicant to build or refurbish access roads, heavy-haul roads, rail spurs, and barge landing

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facilities. Local road access routes also may see increased wear from building-related traffic
associated with the workforce commuting and deliveries. Experience from previous NEPA
reviews of large nuclear power plant construction shows the adverse impacts of making road
improvements are typically minor and temporary.
Construction-related traffic impacts occur as construction-related truck traffic and the workforce
travel to and from the site in competition with the baseline local traffic. At the peak of building
employment, these impacts can be substantial, depending on the characteristics of the access
route(s). To give context to any expected traffic impacts affecting the site and local vicinity, the
NRC staff uses baseline traffic statistics for the principal roadway access routes to and from the
site. State and County transportation departments typically publish annual average daily traffic
counts (FHWA 2018-TN6584) at key points of principal roads and highways. In addition, the
NRC staff analyzes LOS information (FHWA 2017-TN6585) used by transportation planners for
principal road access routes. Table 3-7 provides a summary of LOS values.

Table 3-7
Level of
Service
A
B
C
D
E
F

Level of Service Value Descriptions

General Operating Conditions
Free flow, with low volumes and high speeds.
Reasonably free flow, but speeds beginning to be restricted by traffic conditions.
Stable flow, but most drivers are restricted in the freedom to select their own speeds.
Approaching unstable flow; drivers have little freedom to select their own speeds.
Unstable flow; may be short stoppages.
Forced or breakdown flow; unacceptable congestion; stop-and-go.

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One indicator of a noticeable impact would be a change in a LOS value for a specific roadway.
The PPE and SPE values and assumptions analyzed in this GEIS assume no change in a LOS
value as a result of increased traffic during peak building activities. The staff assumes such
impacts would be of temporary duration (months) and limited to typical day-shift commuting
patterns for the affected roadways. Section 4.4 of RG 4.2, Preparation of Environmental Reports
for Nuclear Power Stations (NRC 2024-TN7081) regarding traffic studies and the timing of peak
building activities recommends that the applicant use LOS studies to demonstrate that its
project falls within the PPE value.

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The NRC staff has determined that as long as the applicable PPE and SPE values and
assumptions are met, the traffic impacts and impacts on the local transportation systems from
building a new reactor can be generically determined to be SMALL and a Category 1 issue. The
staff relied upon the following PPE assumptions to reach this determination:

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• The LOS determination for affected roadways does not change. Mitigation measures may
include implementation of traffic flow management, management of shift-change timing, and
encouragement of ride-sharing and use of public transportation options, such that LOS
values can be maintained with the increased volumes.

3.12.2.1.3 Economic Impacts

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Building new reactor projects has financial and economic impacts on the economic region.
These impacts include construction-related expenditures expected to be made by the applicant
in the local economy, wages and salaries to be paid to construction workers, and the associated
economic activity enabled by these expenditures. Depending on the size of the local economy,
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these beneficial impacts may range from substantial in small rural economies to minimal in large
metropolitan economies, when viewed in the context of the overall economic activity in the
region.

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The NRC staff has assessed the economic impacts of building new nuclear reactors since 2005.
To estimate the economic impacts of anticipated construction-related expenditures made in the
local economy, the NRC relies upon simple economic input-output modeling of those
expenditures to reveal the economic multiplier effect, which estimates the gross output,
employment, and income effects of the direct local expenditures. Economic multiplier effects
depend on several factors including the size of the initial annual expenditures and the diversity
of the local economy. Economic diversity refers to how fast local expenditures leak from the
economy as various rounds of economic activity occur. The more diverse the structure of the
local economy, the longer direct expenditures will circulate in the economy, generating a higher
multiplier effect and greater total impact on output, employment, and income. Because sites can
be located in widely varying local economies, economic multiplier values range widely—typically
between 1.5 and 4. For example, in the case of an employment multiplier of 3, this indicates that
for each direct job created by the construction expenditures, an additional two jobs are also
added as a result of the economic activity generated by the one direct construction job. The
economic impacts of construction and operation of a new reactor are expected to be beneficial;
therefore, this is a Category 1 issue. If, during the project-specific environmental review, the
NRC staff determines that detailed analysis of economic costs and benefits is needed for
analysis of the range of alternatives considered or relevant to mitigation, the staff may require
further information from the applicant.

3.12.2.1.4 Tax Revenue Impacts

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While the greatest tax revenue impacts are generally associated with plant operations, some
revenue impacts would be expected during the building of a plant. These include any local sales
and use taxes paid on local or in-State purchases, service fees from local regulatory bodies
(local licenses and permits, etc.), any local taxes paid by in-migrating workers and their families,
or payments in lieu of taxes arranged by agreement between the applicant and the jurisdiction.
Each site will have differing conditions and agreements with applicants and their contractors and
thus revenue impacts during building must be considered site by site. For example, some States
and local governments may offer incentives for new industrial construction projects, such as
deferred property taxes or sales tax exemptions, which might minimize State and local tax
revenues compared to other sites where such incentives are not offered.

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As with economic impacts, the scale of construction-related tax revenue impacts attributable to
the proposed action may range from substantial in small rural economies to minimal in large
metropolitan economies, when viewed in the context of baseline revenues of the affected taxing
jurisdiction(s) and the size of the proposed action. The staff concludes that if the new reactor
project would not generate tax revenues exceeding 5 percent of the revenue of any affected
jurisdiction or taxing authority during building, then the impacts would be minor and may be
offset by other year-to-year changes in local revenues.

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The tax revenue impacts of construction and operation of a new reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental
review, the NRC staff determines detailed analysis of tax revenue costs and benefits is needed
for analysis of the range of alternatives considered or relevant to mitigation, the staff may
require further information from the applicant.

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The staff’s evaluation of socioeconomic impacts for operating a new reactor primarily focused
on workforce-induced migration, the resulting impacts on local community resources and
infrastructure, and related economic impacts. Tax revenue impacts from an operating reactor
facility also provide beneficial impacts on local taxing jurisdictions. These impacts can vary
considerably from site to site and between building and operations. The NRC staff identified four
environmental issues for analysis of operation of a new reactor:

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Socioeconomic Consequences of Operations

• community services and infrastructure demands (e.g., housing, schools) altered by
operations workers and families migrating into the local economic region; and

• traffic impacts on local site access roadways and associated road networks.

• economic impacts such as employment, economic output, and local labor income; and

• tax revenue impacts, such as sales and property taxes.

3.12.2.2.1 Community Services and Infrastructure

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Based on experience with large LWRs in the current fleet, the staff assumes that a new
reactor’s operations workforce is smaller than its construction workforce, but their presence
would be more permanent. The increased number of workers at nuclear power plants during
regularly scheduled plant refueling and maintenance outages creates a short-term increase in
the demand for temporary housing units in the region around each plant, generally in local
hotels and motels, but also in campgrounds and recreational vehicle parks. However, because
of the short duration and the repeated nature of these scheduled outages, as well as the
general availability of rental housing units (including portable trailers) in the vicinity of nuclear
power plants, employment-related housing impacts would have little or no long-term impact on
the price and availability of rental housing. Refurbishment or unit replacement impacts would be
similar to what is experienced during routine plant refueling and maintenance outages.
Consequently, the staff determined that if the PPE assumption holds, the building-related
impacts on housing are a Category 1 issue. The staff relied upon the following PPE assumption
to reach this determination:

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Experience reviewing new reactors has shown that the operations-related impacts of other
community service and infrastructure resources are bounded by the building-related impacts
and are generally minor. These include impacts on first-responder resources, public utilities
including potable water resources, health care resources, and other public services (e.g.,
community financial aid providers, etc. Minor impacts on public school systems might be
expected because of the addition of children of the operations workforce, as families migrate
into the economic region. However, because much of the building workforce would leave the
area once operation begins, the impacts of the in-migrating operations workforce would be
bounded by the size of the construction workforce’s impact on the school system. If the building
impacts on schools met the criteria for a Category 1 issue, then the operations impacts on
housing and schools, being bounded by that, must also be Category 1 issue. The staff
concludes that, as long as the applicable PPE and SPE assumptions are met, the community
services and infrastructure impacts from operating a new reactor can be generically determined
to be SMALL and mitigation would not be warranted. Therefore, the socioeconomic impacts

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from operating a new reactor are a Category 1 issue. The staff relied upon the following PPE
assumptions to reach this determination:

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• Student:teacher ratios in the affected economic region do not exceed locally mandated
levels after including the school age children of the in-migrating worker families.

3.12.2.2.2 Transportation Systems and Traffic

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Transportation impacts depend on the size of the workforce, the capacity of the local road
network, traffic patterns, and the availability of alternate commuting routes to and from the plant.
Because most sites have only a single access road, there is often congestion on these roads
during shift changes. Because rail and barge facilities would only be used intermittently during
operations, only minimal physical impacts on transportation systems, apart from roadways
(e.g., rail or barge facilities), would be expected during operations.

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The transportation impact of plant operations would be bounded by the peak construction
employment-related impacts and is not likely to result in degradation of LOS values.
Operations-related transportation impacts continue for the life of the plant and become well
established within the affected communities for all nuclear power plants. The increased number
of workers at nuclear power plants during outage activities including unit replacement creates a
short-term increase in traffic volumes, and this impact would vary based on the site location and
size of the plant. Refurbishment impacts including unit replacement would be similar to what has
been experienced during routine plant refueling and maintenance outages. However, because
of the relative short duration of these outages, increased traffic volumes have had little or no
lasting impact. Therefore, as long as LOS values for affected roadways do not degrade, there
would be minor traffic impacts during operations.

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The staff has determined that transportation system and traffic impacts during operations of a
new reactor are a Category 1 issue, as long as the applicable PPE and SPE assumptions are
met. The staff assumes any mitigation measures needed to be able to rely on this GEIS for
construction impacts would be continued during operations, such that LOS values can be
maintained with expected volumes during operations. The staff relied upon the following PPE
assumptions to reach this determination:

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3.12.2.2.3 Economic Impacts

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Economic multiplier effects during operations, including outages or unit replacement activities,
would be bounded by peak construction-related economic impacts, and the staff assumes that
at least minor beneficial economic impacts, such as induced increases in local employment,
labor income, and output, would result. The magnitude of these impacts would depend on the
size and diversity of the local economy. For most anticipated new reactor projects covered by
this GEIS, these impacts would be minor in the context of the economic region in which they
would occur.

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The economic impacts of construction and operation of a new reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental
review, the NRC staff determines the need for detailed analysis of economic costs and benefits

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is needed for analysis of the range of alternatives considered or relevant to mitigation, the staff
may require further information from the applicant.

3.12.2.2.4 Tax Revenue Impacts

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Nuclear power plants and the workers who operate them are an important source of tax revenue
for many local governments and public school systems. Tax revenues from nuclear power
plants mostly come from property tax payments or other forms of payments such as payments
in lieu of (property) taxes, or payments in lieu of taxes payments, although taxes on energy
production have also been collected from a number of nuclear power plants. County and
municipal governments and public school districts receive tax revenue either directly or
indirectly through State tax and revenue-sharing programs.

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In addition to the potentially substantial contribution of property tax revenues, County and
municipal governments in the vicinity of an operating nuclear power plant also receive tax
revenue from sales taxes and service fees from the power plant and its employees. Changes in
the number of workers and the amount of taxes paid to counties, municipal governments, and
public schools can affect socioeconomic conditions in the counties and communities around the
nuclear power plant.

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Outage activities including unit replacement are not expected to have a noticeable effect on the
assessed value of nuclear plants, thus only minimal changes in tax revenues would be
anticipated from future refurbishment activities. Refurbishment activities involving the one-forone replacement of existing components and equipment are generally not considered a taxable
improvement. The addition of any nuclear reactor units beyond the scope of the license may
result in increased assessed value but would be considered under separate licensing actions.
Also, property tax assessments; proprietary payments in lieu of taxes stipulations, settlements,
and agreements; and State tax laws are continually changing the amount of taxes paid to taxing
jurisdictions by nuclear plant owners. These changes are independent of operations activities.

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The tax revenue impacts of construction and operation of a new reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental
review, the NRC staff determines the need for detailed analysis of tax revenue costs and
benefits is needed for analysis of the range of alternatives considered or relevant to mitigation,
the staff may require further information from the applicant.

3.13 Environmental Justice

3.13.1 Baseline Conditions and PPE/SPE Values and Assumptions

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Executive Order 12898, “Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations,” (59 FR 7629-TN1450) directs Federal agencies to
identify and address, as appropriate, potential disproportionately high and adverse human
health and environmental effects of their actions on minority and low-income populations to the
greatest extent practicable and permitted by law. Although independent agencies, such as the
NRC, were only requested, rather than directed, to comply with the E.O., NRC Chairman Ivan
Selin, in a letter to the President, indicated that “the NRC would endeavor to carry out the
measures set forth in the E.O. and the accompanying memorandum as part of the NRC’s efforts
to comply with the requirements of NEPA.” Tribal populations are included within the scope of
the Order. Additionally, an affected population can be a minority population, a low-income
population, or both. In 2004, the Commission issued it’s “Policy Statement on the Treatment of

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Environmental Justice Matters in NRC Regulatory and Licensing Actions” (69 FR 52040TN1009), which states: “The Commission is committed to the general goals set forth in
E.O. 12898, and strives to meet those goals as part of its NEPA review process.”26

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The environmental justice (EJ) issue is not assigned impact levels as Executive Order 12898
requires a determination of whether human health and environmental effects of the proposed
agency action on minority and low-income populations would be disproportionately high and
adverse. Human health and environmental effects have the potential to occur or not occur, and
the effects on minority or low-income populations must be both disproportionately high and
adverse when compared to the effects on the general population. For EJ populations within the
demographic region, an EJ analysis is required to determine whether that population would
experience any disproportionately high and adverse human health or environmental effects. The
NRC will perform an EJ analysis as part of the project specific NEPA analysis prepared for the
proposed agency action.

3.13.2 Environmental Justice Impacts

3.13.2.1

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Potential EJ impacts during construction or operations of a new reactor cannot be determined
without the consideration of project-specific factors, and therefore is a Category 2 issue.
Project-specific factors include the presence, geographic location, and size of specific minority
or low-income populations; impact pathways derived from the plant design, layout, or site
characteristics; or other community characteristics affecting specific minority or low-income
populations. In performing its EJ analysis, the NRC staff will be guided by the Commission’s
“Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and
Licensing Actions,” which is hereby incorporated by reference into this GEIS.

3.14 Fuel Cycle

3.14.1 Baseline Conditions and PPE/SPE Values and Assumptions

3.14.1.1

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As discussed in Section 3.12.1.1, Uranium Fuel Cycle, of the License Renewal GEIS NRC
2024-TN10161), the NRC evaluated the environmental impacts that would be associated with
operating uranium fuel cycle facilities other than reactors in two NRC documents: WASH-1248
(AEC 1974-TN23) and NUREG-0116 (NRC 1976-TN292). The types of facilities and their
environmental impacts considered in these two documents include:

Environmental Consequences of Construction and Operation

Uranium Fuel Cycle Environmental Data

• uranium mining – facilities in which the uranium ore is mined;

In April 2021, the Commission issued Staff Requirements Memorandum M210218B (NRC 2021TN10335) directing the NRC staff to conduct a systematic review of how agency programs, policies, and
activities address environmental justice. The NRC staff submitted its assessment and recommendations
in SECY-22-0025, “Systematic Review of How Agency Programs, Policies, and Activities Address
Environmental Justice” to the Commission in March 2022 (NRC-TN10334). The NRC staff’s review
considered the environmental justice practices of other Federal, State, and Tribal agencies, evaluated the
adequacy of the NRC’s Environmental Justice Policy Statement, and assessed whether the NRC should
address environmental justice beyond the agency’s current practice limited to National Environmental
Policy Act environmental reviews.”

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• uranium milling – facilities in which the uranium ore is refined to produce uranium
concentrates in the form of triuranium octaoxide;

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• uranium hexafluoride (UF6) production – facilities in which the uranium concentrates are
converted to UF6;

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• isotopic enrichment – facilities in which the isotopic ratio of the uranium-235 (U-235) isotope
in natural uranium is increased to meet the requirements of LWRs;

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• fuel fabrication – facilities in which the enriched UF6 is converted to uranium dioxide (UO 2)
and made into sintered UO2 pellets. The pellets are subsequently encapsulated in fuel rods,
and the rods are assembled into fuel assemblies ready to be inserted into the reactors;

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• reprocessing – facilities that disassemble the spent fuel assemblies, chop up the fuel rods
into small sections, chemically dissolve the spent fuel out of sectioned fuel rod pieces, and
chemically separate the uranium in spent fuel from the plutonium for reuse and other
radionuclides (primarily fission products and actinides); and

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• disposal – facilities in which the radioactive wastes generated at all fuel cycle facilities,
including the reactors, are buried. Spent nuclear fuel (SNF) that is removed from the
reactors and not reprocessed was also assumed to be disposed of at a geologic repository.

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In addition to impacts occurring at the above facilities, the impacts associated with the
transportation of radioactive materials among these facilities, including the transportation of
wastes to disposal facilities, were evaluated. The results were summarized in a table and
promulgated as Table S-3 in 10 CFR 51.51(b) (TN250). The analysis in WASH-1248 is based
on the principal environmental considerations for each component of the nuclear fuel cycle, and
the aggregate considerations, normalized to the annual fuel requirement of a 1,000 MWe
(3,000 MWt) model LWR are summarized for the nuclear fuel cycle in Table S-3 (AEC 1974TN23). This normalization is called the “annual model LWR fuel requirement” throughout
WASH-1248 (AEC 1974-TN23).

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Figure 3-4 displays the uranium fuel cycle for the majority of pathways. Table S-3 addresses
their environmental impacts related to the uranium fuel cycle, but this does not include mixed
oxide fuel, as shown in the figure. Additional details about the nuclear fuel cycle are provided in
Section 1.1, Uranium Fuel Cycle, of a Pacific Northwest National Laboratory (PNNL) report
prepared for the NRC (Napier 2020-TN6443). The assumption applied for Table S-3 regarding
plutonium recovered from recycling was that the recovered plutonium would be placed into
storage for future use (see Figure S-1 of WASH-1248 [AEC 1974-TN23]).

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The 1996 version of the License Renewal GEIS (NRC 1996-TN288) found the once-through,
low-enriched uranium (LEU) fuel cycle to be a Category 1 issue with environmental findings of
SMALL. This result was codified into regulations and the findings are provided in 10 CFR
Part 51 (TN250), Appendix B, Table B-1, Summary of Findings on NEPA Issues for License
Renewal of Nuclear Power Plants. Section 4.12.1.1 of the License Renewal GEIS (NRC 2024TN10161) reassessed the environmental effects listed in Table S-3 and concluded that no new
information has been identified that would alter the conclusion in the 1996 version of the
License Renewal GEIS. The analyses provided in Section 4.12.1.1 to the License Renewal
GEIS are incorporated by reference into this analysis. There are potential fuel cycle options
regarding fast spectrum MSRs, as described by Holcomb et al. (e.g., LWR-derived TRU burner)
(Holcomb et al. 2011-TN6943), but they are not considered in this GEIS because of the
continuing development of the related technology bases.

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Figure 3-4

3.14.1.2

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Options of the Current Fuel Cycle which Includes the Table S-3 Uranium
Fuel Cycle. Source: NRC 2019-TN6652.
Other Fissile Fuel Cycles

Fuel cycles based on fissile or fertile materials other than uranium are possible, such as a
thorium fuel cycle in which thorium is irradiated to create fissile uranium-233 (U-233). This fuel
cycle thus would start with mining of thorium, rather than uranium, and would require irradiation
of the thorium in a reactor using U-235–based fuel to generate the necessary U-233. Thorium is
a commercially available material already mined and processed for use in a variety of
commercial products, such as an alloying element in magnesium and in the manufacturing of
lenses for cameras and scientific instruments (RSC 2020-TN6442). Because this fuel cycle
requires neutron transmutation of thorium-232 (Th-232) to U-233 (typically considered to be
from fission of U-235 but could also be from fission of plutonium-239 [Pu-239]), it can be
considered to be partially part of the uranium cycle of Figure 3-4 and partially a separate cycle.
The processes associated with thorium mining, milling, fuel fabrication, reactor use, storage,
reprocessing, and waste disposal should be similar to, but distinct from, those for the uranium
fuel cycle. Enrichment of thorium is unnecessary; however, irradiated thorium requires
processing to obtain the U-233 necessary to this fuel cycle (WNA 2017-TN6668). Thus, a
thorium fuel cycle should only significantly differ from uranium in that conversion of uranium to a
gas (UF6) and subsequent enrichment processes are omitted after initial thorium fuel cycle

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startup; however, reprocessing would be an additional step currently not seen in the oncethrough uranium fuel cycle. The NRC staff assumes that the thorium fuel cycle will not be
significantly different than the uranium fuel cycle, therefore the uranium fuel cycle impacts
should bound the thorium fuel cycle impacts.

3.14.1.3

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The High-Assay Low-Enriched Uranium (HALEU) Availability Program by DOE was developed
to secure a domestic supply of HALEU fuel following the Energy Act of 2020 (DOE 2024TN9790).

DOE High-Assay Low-Enriched Uranium Availability Program

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The HALEU Availability Program will acquire HALEU through purchase
agreements with domestic industry partners and produce limited initial
amounts of material from DOE-owned assets. The HALEU Availability
Program is intended to spur demand for additional HALEU production and
private investment in the nation’s nuclear fuel supply infrastructure – ultimately
removing the federal government’s initial role as a supplier. (DOE 2024TN9790)

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As of the writing of this NR GEIS, DOE is actively seeking partners for enrichment services that
include mining, milling, conversion, and enrichment for the production of HALEU as uranium
hexafluoride. Additionally, DOE is to seeking partners for deconversion of HALEU stored as
uranium hexafluoride to other chemical forms (i.e., metal or oxide) for fuel fabrication purposes.
Finally, DOE is seeking partners to develop criticality benchmarks to assist in the transport
package licensing and certification process. The development of criticality benchmarks is
intended to support further DOE funding opportunities that would result in an NRC Certified
HALEU transportation package.

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DOE has established a HALEU Consortium to further these efforts. The purposes of the
consortium are to:

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•
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•
•

Identify demand estimates for domestic commercial use.
Purchase HALEU made available to members for commercial use.
Conduct HALEU demonstration projects.
Identify HALEU supply chain improvements and reliability.

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The environmental impacts of the DOE HALEU program have been assessed in draft form as
DOE/EIS-0559, Draft Environmental Impact Statement for Department of Energy Activities in
Support of Commercial Production of High-Assay Low-Enriched Uranium (HALEU) (DOE/EIATN10133).

3.14.1.4

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As provided in 10 CFR 51.51(a) (TN250), the environmental data of Table S-3 only apply to CP,
operating license (OL), ESP, or COL applications for light-water-cooled nuclear power reactors.
However, as required in 10 CFR 51.50(b)(3) and 51.50(c) for other than light-water-cooled
nuclear power reactors (i.e., non-LWRs), an ER for an ESP or a COL shall contain the basis for
evaluating the contribution of the environmental effects of fuel cycle activities for the nuclear
power reactor. Any new reactor SNF container (i.e., a storage cask or a transportation container
or package) or an ISFSI and dry transfer system (DTS) facilities for the reactor’s SNF must
satisfy the regulatory requirements of 10 CFR Part 71 (TN301), Packaging and Transportation

Nuclear Fuel Cycle Regulatory Requirements for New Reactors

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of Radioactive Material, 10 CFR Part 72 (TN4884), Licensing Requirements for the Independent
Storage of Spent Fuel, High-Level Radioactive Waste, and Reactor-related Greater Than Class
C Waste, and 10 CFR Part 73 (TN423), Physical Protection of Plants and Materials. Any fuel
cycle facility must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882), Domestic
Licensing of Source Material, and 10 CFR Part 70 (TN4883), Domestic Licensing of Special
Nuclear Material. Any fuel cycle reprocessing must meet the regulatory requirements of 10 CFR
Part 50 (TN249), Domestic Licensing of Production and Utilization Facilities.

3.14.1.5

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Changes in the Nuclear Fuel Cycle since WASH-1248

Many of the nuclear fuel cycle facilities and processes assessed for Table S-3 still exist today.
However, some have undergone several industrial developments and technological advances
that have significantly reduced their environmental effects. As discussed in NUREG-2226, the
Clinch River ESP FEIS (NRC 2019-TN6136), recent changes in the uranium fuel cycle may
have some bearing on environmental impacts. As discussed below, the staff is confident that
the contemporary normalized uranium fuel cycle impacts for LWRs are less than those identified
in Table S-3. This assertion is true in light of the following recent uranium fuel cycle trends in the
United States:

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• Increasing use of in situ leach uranium mining, which does not produce mine tailings and
would lower the release of radon gas. A discussion of this subject is provided in
Section 3.14.2.1.

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• Transitioning of U.S. uranium enrichment technology from gaseous diffusion to gas
centrifugation. The latter process uses only a fraction of the electrical energy per separation
unit compared to gaseous diffusion and U.S. gaseous-diffusion plants that relied on
electricity derived mainly from the burning of coal. A discussion of this subject is provided in
Section 3.14.2.3.

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26
27
28

• Current LWRs are using nuclear fuel more efficiently because of higher levels of fuel
burnup. Thus, less uranium fuel per year of reactor operation is required than in the past to
generate the same amount of electricity (an increase in the time for refueling (from
12 months to 18 months or greater) as applied for Table S-3).

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35
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37
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39
40
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42
43

The values in Table S-3 were calculated from industry averages for the performance of each
type of facility or operation within the fuel cycle. Recognizing that this approach meant that there
would be a range of reasonable values for each estimate, the staff chose the assumptions or
factors to be applied so that the calculated values would not be underestimated. This approach
was intended to make sure that the actual environmental impacts would be less than the
quantities shown in Table S-3 for all LWR nuclear power plants within the widest range of
operating conditions. The staff recognizes that many of the fuel cycle parameters and
interactions vary in small ways from the estimates in Table S-3 and concludes that these
variations would have no impacts on the Table S-3 calculations. For example, to determine the
quantity of fuel required for a year’s operation of a nuclear power plant in Table S-3, the staff
defined the reference reactor as a 1,000 MW LWR operating at 80 percent capacity with a
12-month fuel-reloading cycle and an average fuel burnup of 33,000 megawatt-day(s) per metric
ton of uranium (MWd/MTU). The current LWR fleet is operating with an average factor
approximately 95 percent capacity for peak fuel rod burnup of up to 62,000 MWd/MTU with
refueling occurring at approximately 2-year intervals (NRC 2019-TN6136).

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45

The Table S-3 analysis from the 1970s was also based on most of the electricity generated in
the United States being produced in plants that burn fossil fuels and coal composing the bulk of

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fossil-fuel utilization (AEC 1974-TN23). However, today the energy sources for utility-scale
electrical generation are very diverse with (DOE/EIA-TN10133):

• only 19.5 percent from coal;

• 39.8 percent from natural gas, for which air emissions are much less than those from coal;

• 18.2 percent from nuclear power plants;

6
7

• 21.5 percent from renewables (15.3 percent from non-hydroelectric renewables and
6.2 percent from hydroelectric); and

• Less than 1 percent from petroleum and other sources.

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11
12
13
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15

Therefore, environmental impacts related to air emissions, associated pollutants, and
water/thermal impacts from today’s electrical generation contribution to the nuclear fuel cycle
are clearly less and are bounded by the coal-electrical generation data assessed by
WASH-1248 (AEC 1974-TN23) and found in Table S-3. This trend of decreasing reliance on
fossil fuels for electrical generation will continue, spurred by actions to combat climate change
(DOE/EIA 2020-TN6653). Additional information concerning GHG emission from the fuel cycle
is discussed in Section 3.3.2.2.2.

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17

Based on several of the items discussed above, the 2013 revision of the License Renewal GEIS
states:

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19
20
21

It was concluded that even though certain fuel cycle operations and fuel
management practices have changed over the years, the assumptions and
methodology used in preparing Table S-3 were conservative enough that the
impacts described by the use of Table S-3 would still be bounding.

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23
24
25

With Table S-3 still bounding for particular parts of the LWR nuclear fuel cycle, the following
sections provide a brief background on the components of the nuclear fuel cycle and discuss
their current situation with respect to Table S-3 regarding the advanced nuclear fuel cycle since
the publication of the 2013 revision to the License Renewal GEIS (NRC 2024-TN10161).

3.14.1.6

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28
29
30

As discussed above, a review of past LWR projects has revealed a number of trends, which the
staff assumes will continue for the fuel cycle for new reactors. Therefore, the following
assumptions are made regarding these trends for establishing the PPE for the various new
reactor fuel cycle components and are discussed in Section 3.14.2, Fuel Cycle Impacts:

PPE Assumptions

• increasing use of in situ leach uranium mining,

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33

• transitioning of U.S. uranium enrichment technology from gaseous diffusion to gas
centrifugation for enrichment levels of up to 20 percent,

• using fuel more efficiently in the current LWRs due to higher levels of fuel burnup,

• discharging of fewer spent fuel assemblies per reactor-year, and

• relying less on coal-fired electrical generation plants.

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38

In addition, the following are not part of the above-listed current once-through uranium fuel cycle
trends, but could be applicable to new reactor fuel cycles:

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• Sources of enriched lithium would be from U.S. stockpiles or from foreign sources (Napier
2020-TN6443; GAO 2013-TN6960).

3
4

• The reprocessing capacity would be up to 900 MTU/yr based on analysis in WASH-1248
(AEC 1974-TN23).

• Uranium fuel cycle impacts will bound the thorium fuel cycle impacts.

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8
9
10
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12

The PPE also assumes that the regulatory requirements of 10 CFR Part 40 (TN4882), Domestic
Licensing of Source Material; 10 CFR Part 50 (TN249), Domestic Licensing of Production and
Utilization Facilities; 10 CFR Part 70 (TN4883), Domestic Licensing of Special Nuclear Material;
10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive Material; 10 CFR
Part 72 (TN4884), Licensing Requirements for the Independent Storage of Spent Fuel,
High-Level Radioactive Waste, and Reactor-related Greater Than Class C Waste; and 10 CFR
Part 73 (TN423), Physical Protection of Plants and Materials, are also met.

3.14.2 Fuel Cycle Impacts

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26

The NRC must still evaluate nuclear fuel cycle impacts of the non-LWR fuels to meet its
obligations under NEPA, as has been done for UO2 fuels for LWRs. The NRC has generically
evaluated the environmental effects of the nuclear fuel cycle 27 for LWRs that use uranium fuel.
The results of the evaluation are presented in 10 CFR 51.51 (TN250), Table S-3, Table of
Uranium Fuel Cycle Environmental Data. However, the environmental data of Table S-3 can
only be applied to LWRs that use UO2 fuel. New reactor developers are expected to
predominately still use enriched uranium fuel with close to 20 percent by weight enrichment,
also known as high-assay low-enriched uranium or HALEU. 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 rely on recycled fissile material. Some new reactor developers intend to
build on a thorium/U-233 fuel cycle. To the extent practicable, this section assesses the nuclear
fuel cycle for new reactors for the expected environmental effects compared to the
environmental data provided in Table S-3 where possible.

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28

The NRC staff identified six environmental issues for analysis of fuel cycle impacts associated
with a new reactor:

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34

•
•
•
•
•
•

uranium recovery,
uranium conversion,
enrichment,
fuel fabrication,
reprocessing, and
storage and disposal of radiological wastes.

3.14.2.1

Uranium Recovery

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39

As indicated on the NRC’s public website, uranium recovery focuses on extracting (or mining)
natural uranium ore from the Earth and concentrating (or milling) that ore (NRC 2020-TN6444).
These recovery operations produce a product, called “yellowcake,” which is then transported to
a fuel cycle facility. There, the yellowcake is transformed into fuel for nuclear power reactors. In
27

In the United States, all currently operating commercial plants are LWRs that use uranium for fuel. Therefore, in
this section the term “uranium fuel cycle” is used to describe the current use of nuclear fuel where the principal fissile
material is U-235. The term “nuclear fuel cycle” includes the use of other fissile nuclides, such as U-233 applied in a
thorium-based fuel cycle.

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addition to yellowcake, uranium recovery operations generate waste products, called byproduct
materials, that contain low levels of radioactivity.

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5
6
7
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9
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12
13

For mining activities, the regulatory responsibility depends on the extraction method that the
given facility uses. Specifically, conventional mining (where uranium ore is removed from deep
underground shafts or shallow open pits) is regulated by the Office of Surface Mining, the U.S.
Department of the Interior, and the individual States in which the mines are located. By contrast,
the NRC regulates in situ recovery (formerly known as in situ leach recovery), where the
uranium ore is chemically altered underground before being pumped to the surface for further
processing. Currently, the NRC regulates active uranium recovery operations in New Mexico
and Nebraska, but does not directly regulate the active uranium recovery operations in
Wyoming, Texas, Colorado, and Utah, because they are Agreement States, meaning that they
have entered into strict agreements with the NRC to exercise regulatory authority over this type
of material (NRC 2023-TN10135).

14
15
16
17

The NRC has provided information about the past and current practices for uranium recovery on
the NRC’s public website (NRC 2020-TN6827). The table provided on the public website
compares the features of the three main types of uranium recovery facilities, namely
conventional uranium mills, heap leach/ion-exchange facilities, and in situ recovery facilities.

18
19
20
21
22
23
24

In general, the primary industrial hazards associated with uranium milling are the occupational
hazards found in any metal milling operation that uses chemical extraction, as well as the
chemical toxicity of the uranium itself (NRC 2020-TN6444). Because the uranium produced at
these facilities is not enriched, there is no criticality hazard and little fire or explosive hazard.
Radiological hazards are also low at these facilities, because uranium has little penetrating
radiation and only moderate non-penetrating radiation. The primary radiological hazard is
attributable to the presence of radium in the waste byproduct material (known as “mill tailings”).

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34
35
36

To facilitate the agency’s review of in situ recovery applications, in May 2009 the NRC staff
published the Generic Environmental Impact Statement for In-Situ Leach Uranium Milling
Facilities (NUREG-1910; NRC 2009-TN2559), which addresses common environmental issues
associated with the construction, operation, and decommissioning of facilities, as well as the
groundwater restoration at such in situ recovery facilities, if they are located in particular regions
of the western United States (NRC 2020-TN6828). In addressing environmental issues common
to the in situ recovery process, the NRC staff applied the generic environmental impact
statement for In Situ Leach Uranium Milling Facilities (In Situ Recovery GEIS) as the starting
point for its project-specific environmental review of license applications for new in situ recovery
facilities. Completed project-specific environmental reviews of new in situ recovery facilities can
be found at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1910/ (NRC 2020TN6829). The analysis of the In Situ Recovery GEIS is incorporated by reference.

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38
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40
41
42
43

The Prohibiting Russian Uranium Imports Act, H.R. 1042, bans the import of Russian uranium
(DOE 2024-TN10150). H.R. 1042 passed in the U.S. House of Representatives in December
2023 and the U.S. Senate in April of 2024 and was signed by the U.S. President in May 2024
(NuclearNews 2024-TN10151). The law will allow short-term waivers for Russian imports
through 2027 subject to limitations (NuclearNews 2024-TN10151), which should reduce but may
not fully eliminate the importation of uranium from Russia. Once fully in effect, it is reasonable to
expect uranium recovery operations to increase in the United States.

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45

The analyses for Table S-3 regarding uranium recovery were predicated on active uranium
mining, heap leaching, and large industrial milling facilities (see Appendix C of the In Situ

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Recovery GEIS [NRC 2020-TN6828]). There were no active heap leaching sites and two active
underground uranium mining sites in the United States in 2019 (DOE/EIA 2024-TN10141). As
indicated in the In Situ Recovery GEIS, in situ recovery has removed many of the causes of
harmful uranium recovery impacts because this process does not directly remove the uranium
ore from a site, transport the uranium ore to a large milling facility, and process large volumes of
uranium ore that produce tailing piles and leachate ponds and the associated release of radon
gas. Thus, the in situ recovery process avoids many of the environmental impacts of these past
uranium recovery processing steps. Therefore, the environmental impacts for in situ recovery
are expected to be less than those listed in Table S-3 for uranium recovery facilities and the
impacts would be SMALL. This is a Category 1 issue. The staff relied on the following PPE
assumptions to reach this conclusion:

12
13

• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

14
15

–

Increasing use of in situ leach uranium mining has lower environmental impacts than
traditional mining and milling methods.

16
17

–

Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in less demand for mining and milling activities.

18
19

–

Less reliance on coal-fired electrical generation plants resulting in less gaseous effluent
releases from electrical generation sources supporting mining and milling activities.

20
21
22

• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of
Source Material and 10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive
Material

3.14.2.2

Uranium Conversion

24
25
26
27
28
29
30

The processing involved in converting triuranium octaoxide, (also called “yellowcake”) into UF6
for ease of use in uranium enrichment facilities remains the same as that analyzed for
Table S-3. The only UF6 conversion facility in the United States—the Metropolis Works uranium
conversion facility operated by Honeywell International Inc.—is in Metropolis, Illinois (NRC
2020-TN6837), and is currently in “Operational/idle-ready” status (NRC 2023-TN10140).
Honeywell believes they will be ready to support HALEU demand in the future (ConverDyn
2020-TN6657).

31
32
33
34
35
36
37
38
39

Accident tolerant fuel (ATF) deployment and use with increased enrichment levels would result
in greater amount of yellowcake being processed during uranium conversion to UF 6 to support
increased enrichments. By applying the UxC Fuel Cost Calculator (UxC 2023-TN8086),
increasing enrichment to 8 wt% U‑235 would need approximately 2.1 times more yellowcake
feedstock than the 4 wt% U-235 that underscores Table S-3 environmental data. Increasing
enrichment to 10 wt% U-235 would require approximately 2.6 times more yellowcake for UF 6
conversion than for 4 wt% U-235. Furthermore, increasing enrichment to 20 wt% U-235 would
require approximately 5.2 times more yellowcake for UF 6 conversion than for 4 wt% U-235 (UxC
2023-TN8086).

40
41
42
43
44

The NRC staff assumes that environmental and process control improvements along with new
or amended Federal or State environmental regulations since the publication of WASH-1248 in
1974 would reduce operating uranium conversion facility environmental impacts, maintaining
them within those listed in Table S-3. For example, the RCRA (42 U.S.C. §§ 6901 et seq.;
TN1281) was passed into law in 1976 (EPA 2020-TN6963). Additionally, Honeywell has

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5

completed treatment upgrades to the environmental protection facility to provide enhancements
to meet new fluoride discharge limits (NRC 2019-TN6964). Therefore, NRC staff assumes
Table S-3 will still bound the environmental impacts of a uranium conversion facility operating
today and would be SMALL. This is a Category 1 issue. The staff relied on the following PPE
assumptions to reach this conclusion:

6
7

• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

8
9

–

Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in less demand for conversion activities.

10
11

–

Less reliance on coal-fired electrical generation plants resulting in fewer gaseous
effluent releases from electrical generation sources supporting conversion activities.

12
13
14

• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of
Source Material and 10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive
Material, and 10 CFR Part 73 (TN423), Physical Protection of Plants and Materials.

3.14.2.3

Enrichment

16
17
18
19
20
21

The uranium enrichment process has undergone significant changes since the analysis of
Table S-3 provided in WASH-1248 (AEC 1974-TN23) and NUREG-0116 (NRC 1976-TN292).
That analysis was based on gaseous-diffusion enrichment, which had large energy
requirements and the electricity needed to run the process was produced by coal-electrical
generation plants that featured large air emissions and other environmental conditions, as noted
in Table S-3.

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23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39

Gaseous-diffusion enrichment was the first commercial process used in the United States to
enrich uranium. The enrichment facilities used massive amounts of electricity and as the
centrifuge enrichment technology matured the existing gaseous-diffusion plants became
obsolete (NRC 2020-TN6836). Worldwide they have all been replaced by second-generation
technology, i.e., centrifuge enrichment technology, which requires far less electric power to
produce equivalent amounts of separated uranium. One such nuclear power plant with
centrifuge enrichment technology is the Centrus Energy Corp nuclear power plant located on a
DOE reservation in Piketon, Ohio (NRC 2023-TN10142); Centrus Energy Corp has successfully
demonstrated its HALEU production process and is expanding HALEU production to the rate of
900 kg per year (CEC 2023-TN10144). Another gas centrifuge enrichment facility is the
Louisiana Energy Services (LES) facility in Eunice, New Mexico (NRC 2024-TN10145) which
has been enriching up to 5 wt% Uranium-235 since 2010 (Urenco 2024-TN10146) and has
submitted a license amendment request to enrich up to 10 wt% (Urenco 2024-TN10147).
Historically, there were two gaseous-diffusion plants under NRC purview in the United States
which have been shutdown, namely the facilities at Paducah, Kentucky, and Portsmouth, Ohio
(NRC 2020-TN10162). DOE now holds the certificates for these plants and is in charge of the
safe decommissioning (SAFSTOR) of the nuclear power plants (DOE Undated-TN10148, DOE
Undated-TN10149).

40
41
42
43
44
45

There is a significant difference in energy use between gaseous-diffusion and centrifuge
enrichment technologies. Separative work unit, or SWU, is the standard measure of the effort
required to separate isotopes of uranium (U-235 and uranium-238 [U-238]) during an
enrichment process and is independent of the enrichment process (either gaseous or
centrifuge). Using a SWU calculator (UxC 2023-TN8086) to obtain 1,000 kg of 4 percent by
weight enriched uranium, assuming 0.25 wt% of U-235 in the tails, from a related amount of

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5
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10

natural uranium requires 5,832 SWUs, and to obtain 1,000 kg of 20 percent by weight enriched
uranium (HALEU) requires 41,576 SWUs. The gaseous-diffusion process consumes about
2,500 kilowatt-hour (kWh) per SWU, while modern gas centrifuge plants require only about
50 kWh per SWU (WNA 2020-TN6661). Thus, a centrifuge enrichment facility would consume
approximately 2,100,000 kWh to reach 20 wt% uranium enrichment, while a gaseous-diffusion
plant would need approximately 14,600,000 kWh to reach the 4 wt% uranium enrichment
analyzed in WASH-1248 (AEC 1974-TN23) and assessed in Table S-3. Therefore, for the
enrichment of uranium, Table S-3 would bound the environmental impacts from a centrifuge
enrichment facility to produce HALEU and the impact would be SMALL. This is a Category 1
issue. The staff relied on the following PPE assumptions to reach this conclusion:

11
12

• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

13
14

–

Transitioning of U.S. uranium enrichment technology from gaseous diffusion to gas
centrifugation which requires less electrical usage per SWU.

15
16

–

Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in less demand for enrichment activities.

17
18

–

Less reliance on coal-fired electrical generation plants resulting in fewer gaseous
effluent releases from electrical generation sources supporting enrichment activities.

19
20
21
22

3.14.2.4

Fuel Fabrication

24
25
26
27
28

Fuel fabrication facilities will need to be licensed, constructed, and operated to produce the
necessary new reactor fuel types. The NRC currently regulates several different types of
nuclear fuel fabrication operations. For commercial nuclear power plant fuel, three fuel
fabrication plants processing LEU (up to 5 percent by weight enrichment of U-235) are currently
licensed by the NRC (2020-TN6835):

• Global Nuclear Fuel-Americas in Wilmington, North Carolina;

• Westinghouse Columbia Fuel Fabrication Facility in Columbia, South Carolina; and

• Framatome, Inc. (Framatome), in Richland, Washington.

32
33
34
35
36
37

Two other fuel fabrication plants licensed by the NRC produce nuclear fuel for the U.S. Navy
and can downblend highly enriched uranium (HEU) with other uranium to create LEU reactor
fuel for commercial nuclear power plants. These are the Nuclear Fuel Services plant in Erwin,
Tennessee, and the BWX Technologies, Inc. (BWXT) Nuclear Operations Group plant in
Lynchburg, Virginia. All five of the abovementioned fuel fabrication facilities were in operation at
the time of the WASH-1248 study, as were five other fuel fabrication facilities (AEC 1974-TN23).

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39
40
41
42
43

In Appendix E of WASH-1248 (AEC 1974-TN23), a model fuel fabrication plant that had a
capacity of 3 MTU per day and operated 300 days per year was used to assess environmental
impacts. The model plant lifetime was taken to be 20 years. WASH-1248 also assumed that the
electricity used in fuel fabrication facilities came from coal power plants; some natural gas was
used for process heat and other external resources involved land use and water. At the time of
WASH-1248, fuel fabrication facilities applied a wet process method for UF 6 to UO2 conversion,

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which involves the use of ammonium hydroxide to form an intermediate ammonium diuranate
(ADU) compound prior to final conversion to UO 2.
While WASH-1248 notes that a dry conversion process (DCP) was under development at that
time, several of the above mentioned fuel fabrication facilities now apply a dry process
(AEC 1974-TN23). The ADU process was recognized as creating greater waste management
problems than the dry process. The Global Nuclear Fuel-Americas facility converted to DCP in
1997 (NRC 2009-TN6663) and the Framatome facility converted in 1998 (NRC 2009-TN6664).
The BWXT facility currently only packages customer-provided uranium fuel material into fuel
assemblies (NRC 2003-TN6665). The Nuclear Fuel Services facility could provide a variety of
nuclear fuel services such as converting HEU into LEU or HALEU for use in commercial nuclear
power plants (NRC 2011-TN6666). Only the Westinghouse Columbia Fuel Fabrication Facility
currently applies the ADU process for final conversion to commercial nuclear fuel (NRC 2019TN6472). Available capacity information for the three commercial nuclear fuel fabricators is
provided in Table 3-8. Note that the rod and assembly capacity number may not be similar to
the conversion and pelletizing capacity because UO2 pellets could be provided from an outside
source and the fuel fabricator is only inserting these outside source fuel pellets into cladding
pins and then combining them into fuel assemblies.

Table 3-8
Fabricator
Framatome, Inc.
Global Nuclear
Fuel – Americas
Westinghouse

Light-Water Reactor Fuel Fabrication Capacity

Location
Richland,
Washington
Wilmington, North
Carolina
Columbia, South
Carolina

Conversion
Pelletizing
Rod/Assembly
MTU/yr(a) MTU/d(b) MTU/yr(a) MTU/d(b) MTU/yr(a) MTU/d(b)
1,200
3.4
1,200
3.4
1,200
3.4
1,200

3.4

1,000

2.9

1,000

2.9

1,600

4.6

1,594

4.6

2,154

6.2

(a) WNA 2021-TN10153.
(b) The metric tons of uranium per day (MTU/d) value is based on a current fuel fabrication facility operating
schedule of 350 days per year as opposed to the 300 days assumed in WASH-1248 (AEC 1974-TN23).

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20
21
22
23
24
25

WASH-1248 states that most of the airborne chemical effluents result from the combustion of
fossil fuels to produce electricity to operate the fabrication plant (AEC 1974-TN23). As
previously described, a large percentage of electricity production today is from generation
sources other than coal. Thus, existing and any new fuel fabrication facilities would have lower
air emissions than those assessed in WASH-1248. The level of environmental impacts for
other aspects of fuel fabrication, as presented in Appendix E of WASH-1248, are provided
in Table 3-9.

26
27
28
29
30
31
32

The establishment of commercial fuel fabrication process lines for new reactor designs has yet
to occur (at the time of publishing this GEIS). It is expected that the majority of new reactor fuel
will use HALEU, but it might not be in the form of UO2 sintered pellets. New reactor fuel forms
could be TRi-structural ISOtropic (TRISO) fuel, uranium metal, uranium compound in a molten
salt, or in another yet unidentified form. In addition, there is the potential for a new reactor, likely
a MSR design, to be designed with a thorium-based fuel cycle using fissile U-233 (WNA 2017TN6668).

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Table 3-9

WASH-1248 Fuel Fabrication Environmental Impacts (AEC 1974-TN23)

Environmental Impact
Site Size (acres)
Building Size (ft2)
Annual Water Consumption (gal)
Power Required (MW and
megawatt-hour [MWh])
Annual Natural Gas Usage for
Process Heat (ft3)
Liquid Waste Stream Volume (gpd)

Annual Solid Waste Volume (MT)
Annual Gaseous Airborne Activity
Released (Ci)
Annual Liquid Activity Released
(mCi)
Annual Solid Activity for Disposal
(mCi)

Value
WASH-1248 Comments
A few acres up to a Less than 5 percent of that committed by the
few thousand acres rest of the fuel cycle
100,000
5,200,000
About 0.05 percent of that used by the
model LWR evaluated by WASH-1248
6 MWe and
About 0.5 percent of the electricity of the
1,700 MWe-hr
enrichment plant evaluated by WASH-1248
3,600,000
About 4 percent of that consumed by the
total nuclear fuel cycle
25,000
Combined with about 425,000 gpd of
process cooling water in the holding ponds
prior to release offsite
680
Calcium fluoride precipitate from the liquid
waste stream for retaining on site (11 yd3)
0.005
Less than 0.1 percent of the applicable
10 CFR Part 20 (TN283) limit
40
Less than 10 percent of 10 CFR Part 20
(TN283) limits for release to an unrestricted
area
25
Activity shipped per annual fuel requirement

3.14.2.4.1 TRISO Fuel Fabrication

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12

As described in the previously mentioned PNNL report (Napier 2020-TN6443), TRISO fuel is
composed of fuel particles or seeds less than 1 mm in diameter. Each has a kernel (ca. 0.5 mm)
of uranium oxycarbide (or UO2), and the uranium is likely to be enriched up to 20 wt% of U-235.
This kernel is surrounded by layers of carbon and silicon carbide, giving a containment for
fission products that is expected to be stable up to very high temperatures (up to 1,600°C
(Napier 2020-TN6443). There are two ways in which these particles can be arranged: either in
blocks—hexagonal “prisms” of graphite; or in billiard ball-sized pebbles of graphite encased in
silicon carbide, each with about 15,000 fuel particles and 9 g of uranium. Either way, the
moderator is graphite. A description of a TRISO fuel fabrication process is also provided in
PNNL-29367 and includes the related environmental emissions (Napier 2020-TN6443).

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15
16
17
18
19
20
21
22
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In the United States, BWXT is making HALEU TRISO fuel on an engineering scale, funded by
DOE, and in October 2019 the company announced a planned expansion to commercial scale
within 3 years (WNA 2021-TN10153). As presented in a DOE categorical exclusion document
supporting this work (DOE 2020-TN6735), HEU material would be shipped from the Y-12
National Security Complex in Oak Ridge, Tennessee, to the BWXT facility in Erwin, Tennessee,
for conversion from HEU metal to HEU oxide. BWXT would then ship the HEU oxide to the
BWXT fuel fabrication plant in Lynchburg, Virginia, for downblending and TRISO fabrication.
BWXT was tasked with producing 100 kg of TRISO HALEU fuel. In November 2020, BWXT
announced it had completed its TRISO nuclear fuel line restart project and is actively producing
fuel at its Lynchburg facility (BWXT 2020-TN6756). Test samples of the BWXT TRISO fuel have
been irradiated and examined at the Idaho National Laboratory (INL) Advanced Test Reactor
(Nagley 2020-TN6739). In 2022 the Department of Defense Strategic Capabilities Office
selected BWXT for creation of the Project Pele microreactor. The reactor core will use TRISO

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produced by BWXT (BWXT 2022-TN10154). The production of this TRISO fuel is being
conducted under existing NRC special nuclear material (SNM) licenses and associated
environmental assessments (EAs). For the BWXT Lynchburg facility, the license renewal EA,
issued in 2006 for a 20-year period under Materials License SNM-42, concluded the BWXT
operations would not result in a significant impact on the environment where airborne and liquid
effluent releases along with public and occupational doses are below regulatory limits (71 FR
16348-TN6785). Therefore, this EA covers the environmental impact of producing 100 kg of
TRISO HALEU fuel under DOE funding.

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A potential new fuel fabricator for TRISO is X-Energy LLC (X-Energy 2020-TN6736). X-Energy
has also been producing TRISO fuel on an engineering scale and announced irradiation testing
in May 2020 to be performed at the Massachusetts Institute of Technology Nuclear Reactor
Laboratory’s 6 MW Massachusetts Institute of Technology reactor (WNN 2020-TN6740).
X-Energy has developed a pilot TRISO fuel fabrication process and presented an overview of
this process to the NRC and during a national HALEU webinar (Pappano 2018-TN6738,
Pappano 2020-TN6737).

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In 2023, Ultra Safe Nuclear Corporation (USNC) and Framatome established a joint venture to
produce TRISO (USNC 2023-TN10158). USNC has constructed a pilot fuel fabrication facility
for production of TRISO fuel. USNC has produced TRISO for the National Aeronautics and
Space Administration, though for use as a nuclear propulsion technology for spacecraft (USNC
2023-TN10159). The production of this TRISO fuel is being conducted under existing NRC SNM
licenses and associated EAs. Operation of the facility is covered by the Framatome license
SNM-1227 and its associated EAs.

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A direct comparison of existing ADU and DCP fabrication and industry-level TRISO fuel
fabrication processes cannot be made at this time. The BWXT TRISO work is being conducted
under an existing NRC SNM license but production quantity is limited. Based on the available
public information, once the UF6 feedstock is converted to a solid form, the X-Energy TRISO-X
process and NRC’s experience with BWXT TRISO fuel fabrication licensing both have similar
steps that feature environmental impacts comparable to or less than those of the ADU (the fuel
fabrication process associated with Table S-3) and the current DCP fuel fabrication processes
(Pappano 2020-TN6737).

3.14.2.4.2 Metallic Uranium Fuel Fabrication

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It is anticipated that several new reactor designs, such as microreactors and liquid sodiumcooled reactors, could use a form of metal uranium alloy fuel. Such a fuel type has been
employed in a variety of research and test reactors. Supplies of metallic HALEU could become
available to commercial developers, at least initially, from DOE’s surplus HEU stockpiles. One
initial source of metallic uranium is recycled material from the Experimental Breeder Reactor-II
(EBR-II) at INL, but it could also be provided by DOE if surplus HEU from the U.S. government’s
nuclear weapons program is made available for commercial nuclear fuels. The uranium material
from EBR-II, up to 10 MT, will be melted into ingots and could be cast into reactor components
(DOE 2019-TN6757). INL has developed the Hybrid Zirconium Extraction process, which is
used to remove cladding from the fuel, thereby allowing downblending of metallic HEU into
HALEU casting (INL 2019-TN6758). The first castings for a new reactor were made in late 2019
(Morning Consult 2019-TN6759). INL is also prepared to recover up to 10 MT of former EBR-II
fuel for transition into appropriate fuel forms for new reactor fuel developers (DOE 2023TN10160). INL awarded 5 MT of the former EBR II fuel to Oklo Inc. for recycling and
repurposing for Oklo’s design (DOE 2023-TN10160).

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For the case where the initial supply of metallic uranium fuel for a new reactor is supplied from
DOE’s surplus HEU stock, all of the environmental impacts prior to fuel fabrication already
occurred during U.S. government processes years ago. HALEU fuel could use processed spent
EBR-II fuel (DOE/EA-2087; DOE 2019-TN6757). Thus, any environmental impacts from the
processing of metallic fuel from DOE sources for new reactors related to past mining, milling,
enrichment, and conversion have been accounted for in the WASH-1248 analysis (AEC 1974TN23) and are provided in Table S-3. If the HALEU feedstock is taken from unprocessed
irradiated fuel (i.e., EBR-II or spent Navy fuel), then there will be an environmental impact
associated with reprocessing the irradiated fuel, likely similar to the impacts associated with
previously processed irradiated EBR-II fuel, as described in DOE/EA-2087 (DOE 2019TN6757). Thus, future commercial production of metallic HALEU fuel would have environmental
impacts similar to those previously discussed for all steps prior to fuel fabrication.

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An overall fuel fabrication process is presented in Section 1.1 of the PNNL report entitled Metal
Fuel Fabrication Safety and Hazards (LaHaye and Burkes 2019-TN6961). The metal fuel
fabrication steps, as provided by LaHaye and Burkes (2019-TN6961), are as follows:

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1. Feedstock must be prepared from ore. This includes dissolution, purification, and chemical
conversion to the desired chemical state for the next step. Feedstock can also be prepared
from used fuel through reprocessing. Enrichment will typically take place between
purification and conversion to the final chemical state for reduction but is outside the scope
of this effort. (These steps are addressed previously in this section of this GEIS.)

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2. Feedstock must then be reduced to metal. This is traditionally achieved by
bomb/metallothermic reduction, but other means can also be employed to convert feedstock
to metal.

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3. The metal is alloyed with the desired alloying agent(s) to create a binary, ternary, or other
alloy.

4. The alloy is cast to form a fuel billet.

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5. The fuel billet is machined and/or thermomechanically processed to get it into a desired
form.

6. The formed fuel billet is clad and collected into fuel assemblies.

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Each of the above metal fuel fabrication process steps is described in detail in subsequent
sections by LaHaye and Burkes (2019-TN6961) and is incorporated by reference.

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For assessing the environmental impacts of metal fuel fabrication, the level of impacts is likely to
vary with the source of metal fuel feedstock. If the fuel material is being supplied directly from
the enrichment facility or was from downblended HEU, the only radiological hazard would be
from the uranium itself. Such a feedstock source should also not need any further purification.
For recycled or reprocessed used fuel, the purification to remove fission products and TRU
elements could be an initial step in the metal fuel fabrication facility. The effectiveness of this
purification process in removing the highly radioactive non-fuel nuclides could affect the kind of
processing protections (e.g., remote operations in a highly shielded hot cell versus a glovebox)
necessary in the subsequent fabrication steps.

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Outside of the expected radiological impacts, the effluent releases and wastes streams from the
above process steps are not expected to be significantly different than those of most metal
fabrication facilities. As described by the European Bank for Reconstruction and Development
(EBRD Undated-TN6941) and by LaHaye and Burkes (2019-TN6961), there are likely to be a

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number of waste streams from metal fabrication. Air emissions from volatile chemicals, fumes,
and dust/particulates would be generated from various process steps involving melting,
degreasing, cleaning, welding, and grinding operations. Solid waste in the form of chips and
scrap metal could be generated from machining, milling, and thermomechanical treatments.
Wastewater could also be generated containing various chemical wastes due to the mentioned
degreasing, cleaning, treatments, and grinding operations.

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The NRC staff assumes a metal fuel fabrication facility would have the appropriate process
controls (e.g., glove boxes and hot cells as appropriate), ventilation filters (e.g., high-efficiency
particulate air [HEPA] and charcoal filter beds), and monitoring to minimize the amount of waste
generated and associated environmental impacts. Environmental impacts could be bounded by
current fuel fabrication processes. However, there could be noticeable waste streams from
casting and from stabilizing uranium scraps (LaHaye and Burkes 2019-TN6961). Therefore, due
to the lack of environmental impact information for new reactor metal fuel fabrication, the NRC
staff cannot readily assess an environmental impact for such fuel fabrication in relationship to
WASH-1248 and Table S-3.

3.14.2.4.3 Nuclear Fuel in Molten-Salt Reactors

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A new reactor classified as a MSR is one where a molten salt is used as the working fluid for
heat, transferring the energy from the nuclear core to an industrial process, such as electrical
generation or industrial heat processes. The nuclear fuel could be in a form described above in
the MSR’s own fuel channel. There are also proposed MSR designs in which the nuclear fuel
will be mixed in the molten salt and the reactor will be specifically designed so that the reactor
vessel’s configuration is such that the nuclear core physics support criticality (i.e., a liquid-fuel
MSR). As indicated by the World Nuclear Association (WNA), “in the normal or basic MSR
concept, the fuel is a molten mixture of lithium and beryllium fluoride salts with dissolved LEU
(U-235 or U-233) fluorides (UF4)” (WNA 2021-TN7072). As further indicated by the WNA,
“chloride salts have some attractive features compared with fluorides, in particular the actinide
trichlorides form lower melting point solutions and have higher solubility for actinides so can
contain significant amounts of transuranic elements” (WNA 2021-TN7072). The type of nuclear
fuel could be based on any of the fissile isotopes in the form of HALEU U-235, a mixture of
uranium and plutonium (TRU mixture with U-235, Pu-239, and U-238 in a fast neutron
spectrum), or thorium-based U-233. A number of MSR developers are examining a variety of
molten-salt types (Flanagan 2017-TN6742). Discussions of nuclear fuel salts likely to be
employed in MSRs (chloride- and fluoride-based salts) and the general characteristics of
reactors that would use those types of salts are provided in Chapter 2 of McFarlane et al. (2019TN6741).

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Two prior productions of liquid-fuel MSRs could be used as an indication of the fuel preparation
impacts for this type of nuclear fuel (McFarlane et al. 2019-TN6741): the Aircraft Reactor
Experiment (ARE) in 1954, and the Molten-Salt Reactor Experiment (MSRE). McFarlane et al.
(2019-TN6741) provide a description of the processing of the ARE fuel in Section 2.2.1 of their
report, Fuel Loading at ARE:

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At the ARE, Na2UF6 was added to an initially barren mixture of sodium and
zirconium fluorides. The procedure to add the ARE fuel involved the successive
connection of numerous small concentrate containers to an intermediate transfer
pot. The pot was then connected to the fuel system, which injected the
concentrate into the pump tank above the liquid level. Since the ARE was not
optimized for breeding, its fuel salt contained a higher concentration of uranium.

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The ARE final fuel mixture consisted of 53.09 mole percent NaF, 40.73 mole
percent ZrF4, and 6.18 mole percent UF4, with 235U enriched to 93.4 weight
percent. The ARE fuel salt 235U concentration was increased 8.8 percent over the
course of operations (from 0.383 g/cc to 0.416 g/cc) as operational power was
increased.
McFarlane et al. (2019-TN6741) provide the following description of the MSRE fuel in
Section 2.2.2 of their report, Fuel Loading at MSRE:
The MSRE reactor fuel mixture nominally consisted of 65 7LiF, 29.1 BeF2,
5 ZrF4, and 0.9 UF4 (mole percent). At MSRE, 7LiF-UF4 (73-27 mole %) was
separately synthesized and incrementally dissolved into barren carrier salt to
start and maintain nuclear operation. Both the MSRE coolant and the flush salt
were a binary mixture of 66 mole percent LiF in BeF 2. Initial operation
employed 33 weight percent enriched uranium. The operational fuel salt
volume was roughly 2,067 liters. All of the lithium used was assayed to be at
least 99.99 percent 7Li. In 1968, the uranium was removed from the fuel salt
and replaced with nearly pure 233U. The last few refueling capsules in
1969 contained PuF3 (94 weight percent 239Pu).

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McFarlane et al. (2019-TN6741) discuss the processes for synthesizing the carrier salt and
related chemical hazards in Chapter 3 of their report. In addition, it is expected there would be
onsite processing to add fissile material and to remove certain fission products to maintain MSR
operations. While these processes would be like other industrial hazards associated with
producing chloride- and fluoride-based compounds, they were not part of the analysis in
WASH-1248 (AEC 1974-TN23) and are not addressed in Table S-3.

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An additional consideration for the liquid-fuel MSRs is that the fission products dissolved in the
fuel salt could be continuously removed in an adjacent online reprocessing loop and replaced
with fissile uranium, plutonium and other actinides, or, potentially, fertile Th-232 or U-238 (WNA
2021-TN7072). Because this is a series of actions that would occur during operations, it is not a
fuel fabrication process. For this situation, once the MSR begins operation, only the
manufacturing of the chemical form of the fissile material being produced to be compatible
with the respective chemistry of the molten salt to be delivered to the MSR is part of the
fuel preparation process. Potential waste processing and waste forms associated with
MSRs are documented by Riley et al. (2018-TN6942).

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If the MSR design has a separate fuel channel from the molten-salt coolant then NRC staff
assumes the fuel fabrication environmental impacts as described above to be similar to the
nuclear fuel form being employed in the reactor design (i.e., oxides, TRISO, and metal).
However, due to the lack of environmental impact information about generating liquid-fuel
molten salt, the NRC staff cannot readily assess an environmental impact of such fuel
fabrication in relationship to WASH-1248 (AEC 1974-TN23) and Table S-3.

3.14.2.4.4 Fuel Fabrication Conclusions

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For the assessment of environmental impacts, Table S-3 is expected to bound the impacts for
new reactors that rely on uranium oxycarbide/UO2 fuels if such fuel fabrication is applying the
existing processes of the NRC-licensed fuel fabrication facilities resulting in SMALL impacts. If
not, the impacts from new reactor fuel fabrication would need to be bounded by the values
provided in Appendix E of WASH-1248 (AEC 1974-TN23), as listed in Table 3-9. Based on the

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assumption of meeting these values, fuel fabrication is a Category 1 issue. The staff relied on
the following PPE assumptions to reach this conclusion:

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• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

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–

Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in fewer discharged fuel assemblies to be fabricated each year and due to
longer time periods between refueling

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Less reliance on coal-fired electrical generation plants resulting in less gaseous effluent
releases from electrical generation sources supporting fabrication

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Any new reactor fuel fabrication that cannot be bounded by WASH-1248 (AEC 1974-TN23),
namely metallic fuel and liquid-fuel MSRs, requires a discussion of the anticipated fuel
fabrication process and environmental impacts in the project-specific application. New reactor
applications in these cases must include enough information to support the staff’s review for
reaching an environmental finding. The information needs identified in the PNNL report (Napier
2020-TN6443) should be provided in the new reactor application.

3.14.2.5

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As discussed in Section 1.6.1 of SECY-2011-0163 (NRC 2011-TN6830), the NRC staff
considers reprocessing to be defined as the separation of SNF into its constituent components
of isotopes of uranium, fission products, and TRU nuclides by aqueous and nonaqueous
chemical processing of irradiated fuel for the purpose of recovering reusable fuel material. This
definition encompasses the types of materials that would be produced in reprocessing and the
various methods of separation that have been proposed. Reprocessing of SNF could occur for
some types of new reactor fuels (e.g., fissile material circulating in the molten-salt coolant or a
new reactor designed to use reprocessed SNF) and could be internal to the operation of the
reactor at the site or could be conducted externally at a remote reprocessing facility. Therefore,
the environmental impacts of reprocessing new reactor fuel are addressed in this section.

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At the time WASH-1248 was published, only U.S. government reprocessing facilities were in
operation and applying the plutonium uranium reduction extraction (PUREX) process. 28 There
were no operational commercial SNF reprocessing facilities. Three U.S. commercial
reprocessing facilities were anticipated to be operational later in the 1970s (AEC 1974-TN23).
Thus, WASH-1248 and related reports in support of Table S-3 evaluated the environmental
impacts of PUREX reprocessing as being maximized for either of the two fuel cycles: uranium
only and full recycle. Based on a court decision, the Commission directed the staff to prepare a
supplement to WASH-1248 to establish a basis for identifying environmental impacts associated
with fuel reprocessing and waste management activities that are attributable to the licensing of a
model LWR. These environmental impacts were documented in NUREG-0116, Environmental
Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle
(NRC 1976-TN292). No U.S. commercial SNF reprocessing facilities are in operation as of

Reprocessing

PUREX involves the dissolution of irradiated nuclear fuel in nitric acid, followed by separation of the uranium,
plutonium, and fission products by solvent extraction using a mixture of tributyl phosphate in an organic diluent.

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today, and there are no licensing actions to construct and operate such a nuclear facility at the
time of this GEIS; however, DOE and a group composed of commercial entities, universities,
and national laboratories are evaluating the potential for recycling and reprocessing spent
nuclear fuel (ARPA-E 2022-TN10126).

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WASH-1248 Table F-1 provides a summary of environmental considerations for irradiated fuel
reprocessing normalized to the model LWR annual fuel requirement (AEC 1974-TN23). The
table is based on the collective operation of the three anticipated reprocessing facilities,
normalized to an annual capacity of 900 MTU/yr, to serve as the selected model reprocessing
plant. This capacity is equivalent to the annual fuel requirements of approximately 26 model
LWRs at 1,000 MWe each, or 3.46 × 10-2 MTU/yr-MWe.

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The level of impacts of reprocessing in WASH-1248 (AEC 1974-TN23) correspond to
approximately a quarter of the current nuclear operating fleet. This amount of reprocessing
capability could support a large number of new reactors. Thus, it is likely that the capacity of an
offsite reprocessing process related to one new reactor would be significantly under
900 MTU/yr. Therefore, this is a Category 1 issue based on the bounding assumption that the
reprocessing capacity for the new reactor, if pursued as an integral part of its fuel cycle, would
be less than 900 MTU/yr, and that the contents of Table S-3 would bound the environmental
impacts.

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Table 2-10 in the Environmental Survey of the Reprocessing and Waste Management Portions
of the LWR Fuel Cycle (NUREG-0116) provides a summary of the impacts of reprocessing and
waste management per reference reactor-year (RRY) for a 1,000 MWe reactor (assumed to be
operating at 80 percent of its maximum capacity for 1 year) (NRC 1976-TN292). Based on the
best available information applied in NUREG-0116, the impacts as summarized in Table 2.10 of
this NUREG are slightly different from those in WASH-1248 (AEC 1974-TN23). When these
impacts are included in the total impacts of the uranium fuel cycle attributable to a single reactor
(see new Total column in Table 2.10 of NUREG-0116), the total values are not substantially
different from those in WASH-1248; the difference in values is not sufficient to affect the NRC
staff’s impact determination in this GEIS.

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Under the Integral Fast Reactor program (ANL 2017-TN6832), a form of pyroprocessing
(ANL 2016-TN6831), a pyrochemical/electrochemical reprocessing (PER) method, was
developed and tested using the EBR-II fuel and facilities. Pyroprocessing is a nonaqueous
reprocessing process in which spent fuel is subjected to high temperatures (typically over 600°C
[equivalent])] to facilitate physical or chemical processes for the purpose of separating and
recovering fissile and fertile materials (NRC 2011-TN6830). PER is a pyroprocessing operation
involving selective reduction and oxidation in molten salts or metals to recover nuclear fuel
materials, and management of the resulting waste (NRC 2011-TN6830). However, the Integral
Fast Reactor program was cancelled, and further development of PER has been limited since
then (Frank et al. 2015-TN6833). Renewed interest in applying PER for reprocessing new
reactor fuel has been expressed, so the environmental impacts of a potential PER method are
considered in this GEIS. In support of the treatment of sodium-bonded SNF, DOE has evaluated
several methods of reprocessing including a PUREX-based and a PER-based treatment (DOE
2000-TN6834). As provided in Table S-4 of DOE/EIS-0306 (DOE 2000-TN6834), the PER
environmental impacts were shown to be less than those associated with a PUREX treatment
process with one exception where there is a small difference in the volume of high-level waste
generated (18 m3 for PER vs. 5.6 m3 for PUREX) (DOE 2000-TN6834).

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The NRC staff finds the above conclusions provided in NUREG-0116 support the conclusions in
WASH-1248 resulting in SMALL impacts. Additionally, for the same mass of spent fuel
processed as in the PUREX process described in WASH-1248 (AEC 1974-TN23) and
NUREG-0116 (NRC 1976-TN292), these environmental impacts should bound or be similar to a
PER-based treatment process. This is a Category 1 issue. The staff relied on the following PPE
assumptions to reach this conclusion:

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• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

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–

Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in fewer discharged fuel assemblies to be reprocessed each year

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–

Less reliance on coal-fired electrical generation plants resulting in less gaseous effluent
releases from electrical generation sources supporting reprocessing

• Reprocessing capacity up to 900 MTU/yr

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• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) “Domestic Licensing
of Source Material,” 10 CFR Part 50 (TN249), “Domestic Licensing of Production and
Utilization Facilities,”10 CFR Part 70 (TN4883), “Domestic Licensing of Special Nuclear
Material,” 10 CFR Part 71 (TN301),” Packaging and Transportation of Radioactive Material,”
10 CFR Part 72 (TN4884),” Licensing Requirements for the Independent Storage of Spent
Fuel, High-Level Radioactive Waste, and Reactor-related Greater Than Class C Waste,”
and 10 CFR Part 73 (TN423), “Physical Protection of Plants and Materials.”

3.14.2.6

Storage and Disposal of Radiological Wastes

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As with previous LWRs, the NRC must analyze the environmental impacts of the generation of
radioactive wastes by a new reactor and their safe storage and ultimate disposal. Appendix G of
WASH-1248 presents the analysis of the environmental impacts of managing radioactive
wastes from the nuclear fuel cycle activities (AEC 1974-TN23). The analysis is for radioactive
wastes that can be categorized as HLWs and other than high-level, or LLRWs. HLWs,
generated at fuel reprocessing plants, contain fission products separated from fissile material
recovered from irradiated fuel. LLRWs result from operations involving UF 6 production, fuel
fabrication, and fuel reprocessing. These include all wastes, regardless of concentration
or specific activity, that are not designated as HLWs.

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While WASH-1248 states the LLRW, which is generated during fuel cycle operations, is variable
and difficult to estimate, the total waste volume is estimated to be approximately 14,000 ft 3
(AEC 1974-TN23). This analysis also assumes that, with no further compaction of the waste,
the final volume of packages containing the waste could approximate 20,000 ft 3 per annual
model LWR fuel requirement. As discussed in Section 3.15, Transportation of Fuel and Waste,
in this GEIS, this is a fraction of the annual LLRW from all U.S. sources shipped to the four
Agreement State-licensed LLRW disposal facilities.

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The analysis in WASH-1248 (AEC 1974-TN23) was based on lower burnup levels than are
currently allowed for the current fleet of LWRs. The higher burnup levels result in greater
utilization of the uranium fuel along with corresponding greater efficiency in extracting energy
from the fuel. This has also resulted in extended time between refueling and the removal of
fewer fuel assemblies per reactor-year.

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WASH-1248, while recognizing that a HLW disposal facility, which includes disposal of SNF, did
not yet exist, did state that the U.S. Atomic Energy Commission (AEC) was proceeding on a
program to design, construct, and operate a surface (or near-surface) facility in which the
solidified commercial HLW in sealed canisters would be stored (AEC 1974-TN23). However,
this program was never completed. Rather, in the late 1970s, the NRC reexamined an
underlying assumption used in licensing reactors up to that time, namely that a repository could
be secured for the ultimate disposal of spent fuel generated by nuclear reactors, and that spent
fuel could be safely stored in the interim (NRC 2014-TN4117). This analysis was later codified
into NRC regulations under 10 CFR 51.23 (TN250), “Temporary storage of spent fuel after
cessation of reactor operation – Generic determination of no significant environmental impact”
(49 FR 34658-TN3370), or the Waste Confidence decision.

3.14.2.6.1 Waste Confidence and the Evaluation of Continued Storage

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The complete history of the Waste Confidence decision is provided in Section 1.1, History of
Waste Confidence, of NUREG-2157, Generic Environmental Impact Statement for Continued
Storage of Spent Nuclear Fuel (NRC 2014-TN4117) and is incorporated by reference. As a
result of legal actions involving the unknown timing of an operational geologic repository for the
permanent disposal of SNF, the NRC developed and published NUREG-2157 and revised
10 CFR 51.23 (TN250), which became “Environmental impacts of continued storage of SNF
beyond the licensed life for operation of a reactor” (79 FR 56238-TN4104).

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NUREG-2157 analyzes the environmental impacts of continued storage of spent fuel
(NRC 2014-TN4117). In it, the NRC analyzed the direct, indirect, and cumulative effects of
continued storage for three timeframes:

• short-term – 60 years beyond licensed life for reactor operations;

• long-term – 100 years beyond the short-term storage time frame; and

• indefinite – indefinite storage and handling of spent fuel.

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These timeframes are discussed in more detail in Section 1.8.2 of NUREG-2157 (NRC 2014TN4117). The locations of the storage sites related to these impacts were assessed for
at-reactor storage, away-from-reactor storage, and cumulative impacts when added to other
past, present, and reasonably foreseeable activities. The analyses contained in NUREG-2157
provide the regulatory basis for the revisions to 10 CFR 51.23 (TN250), in which 10 CFR
51.23(a) states:

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The Commission has generically determined that the environmental impacts of
continued storage of SNF beyond the licensed life for operation of a reactor are
those impacts identified in NUREG–2157, “Generic Environmental Impact
Statement for Continued Storage of Spent Nuclear Fuel.”

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The impact levels determined in NUREG-2157 of at-reactor storage, away-from-reactor storage,
and cumulative impacts of continued storage when added to other past, present, and
reasonably foreseeable activities are summarized in Table 6-4 of NUREG-2157 (NRC 2014TN4117). The impact levels are denoted as SMALL, MODERATE, and LARGE as a measure of
their expected adverse environmental impacts. Most impacts were found to be SMALL and
SMALL to MODERATE. For some resource areas, the impact determination language is
specific to the authorizing regulation, Executive Order, or guidance. Impact determinations that
include a range of impacts reflect uncertainty related to both geographic variability and the

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temporal scale of the analysis. As a result, based on analyses performed in NUREG-2157, the
NRC assumes that further project-specific analysis would be unlikely to result in impact
conclusions with different ranges. The analyses of NUREG-2157 were codified into 10 CFR
51.23 (79 FR 56238-TN4104).

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Many of the assumptions provided in Section 1.8.3, Analysis Assumptions, and subsequent
analysis in NUREG-2157 are independent of the fuel type because they involve onsite impacts
related to the siting, operation, and maintenance of the ISFSI and DTS facilities over all
timeframes during continued storage (NRC 2014-TN4117). For example, the waste
management resource area involves radioactive and chemical wastes generated by the
operation of the ISFSI itself and does not directly involve the SNF in the storage casks. Only a
select few topics considered in NUREG-2157 have a connection with the SNF itself and how it
could result in offsite environmental impacts, namely related to “Transportation,” “Public and
Occupational Health,” “Postulated Accidents,” and “Potential Acts of Terrorism.”

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For the transportation of SNF and for public and occupational health, the staff concluded in
NUREG-2157 that the radiological doses would be expected to continue to remain below the
regulatory dose limits during continued storage and all of the related activities would have small
environmental impacts (NRC 2014-TN4117). The staff reached this conclusion in Sections 4.16
and 4.17 of NUREG-2157 because the operations during continued storage would have a
smaller workforce, lower volume of traffic and shipment activities, and continued storage
represents a fraction of the activities occurring during reactor operations, as previously analyzed
in the License Renewal GEIS (NRC 2024-TN10161) and in other NRC studies.

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Regarding the analysis of postulated accidents in NUREG-2157 (NRC 2014-TN4117), any SNF
must be safely stored and decay heat must be appropriately removed once the SNF is removed
from the reactor. This includes the protection from and the mitigation of severe accidents, or
beyond-design-basis accidents, which are accidents that may challenge safety systems at a
level higher than that for which they were designed.

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The concerns about severe accidents within an ISFSI, whether involving at-reactor or awayfrom-reactor storage, were analyzed in NUREG-2157 (NRC 2014-TN4117). The lowest
consequences events with any radiological release involved dropping a cask. The highest
consequences were associated with an impact on the storage cask followed by a fire, such as
could occur after an aircraft impact. In all cases, the staff determined the likelihood of the event
would be very low and the environmental risk of an accident would be small. The consequences
described for cask drops at an ISFSI also provided some insight into the consequences of
severe accidents in a DTS. Compliance with NRC regulations for spent fuel handling and
storage would likely make the risk of severe accidents in a DTS small. In addition, the
consequences of any severe accident in a DTS would likely be comparable to or less than that
for the cask drop accident described above. This resulted in the staff concluding in
NUREG-2157 that the likely impacts from activities in a DTS also would be small.

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An assessment of the risks that could potentially result from acts of terrorism or radiological
sabotage was also provided in NUREG-2157 (NRC 2014-TN4117). The assessment was
based, in part, on the analysis provided in the licensing of the Diablo Canyon ISFSI and
accounted for the security and protective measures required by NRC regulations (see
Section 4.19 of NUREG-2157). The staff determined that the potential for theft or diversion of
LWR spent fuel from the ISFSI with the intent of using the contained SNM for nuclear explosives
is not considered credible because of the following:

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• the inherent protection afforded by the massive reinforced concrete storage module and the
steel storage canister;

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• the unattractive form of the contained SNM, which is not readily separable from the
radioactive fission products; and

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• the immediate hazard posed by the high radiation levels of the spent fuel to persons not
provided with radiation protection.

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The staff concluded in NUREG-2157 (NRC 2014-TN4117) that for acts of terrorism, even
though the environmental consequences of a successful attack could be large, the very low
probability of a successful attack ensures that the environmental risk would be small for
operational ISFSIs and DTSs during continued storage.

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Finally, the Commission, in the Continued Storage rulemaking, reclassified the offsite
radiological impacts of SNF and HLW disposal as a Category 1 issue; no impact level was
assigned and the finding column entry was revised to address the existing radiation standards
(79 FR 56238-TN4104). Thus, the Commission has concluded that the impacts would not be
sufficiently large to require the NEPA conclusion, for any plant, that the option of extended
operation under 10 CFR Part 54 (TN4878) should be eliminated (see Table B-1 in 10 CFR
Part 51 [TN250]).

3.14.2.6.2 Continued Storage of Spent Advanced Fuel

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Many of the new reactor designs currently under development were not part of the analysis of
NUREG-2157 (NRC 2014-TN4117), as noted in Section 1.8.6, Issues Eliminated from Review in
this GEIS. This is likely due to information provided in a report to Congress in August 2012
(NRC 2012-TN6670), which stated:

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Spent nuclear fuel storage regulations in 10 CFR Part 72 are generally broad
enough to address new types of fuel associated with advanced reactor designs.
However, minor modifications may be necessary to address new design features
from any new class of cask storage technologies associated with advanced
reactor fuels. The NRC would need to evaluate the adequacy of new storage
cask designs for onsite storage of advanced LWR and non-LWR fuel designs
and any other radioactive components not previously reviewed as part of the
current LWR technology. The NRC would consider how cask designs may be
affected by different discharge and loading operations, since discharged fuel may
not be housed in traditional spent fuel pools. Other challenges may involve
stacking spent fuel for non-LWRs during refueling operations, as well as
detecting, segregating, and processing damaged fuel.

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Thus, with only limited information about SNFs concerning high-temperature gas-cooled
reactors or liquid metal fast reactors, NUREG-2157 designated SNF from these types of
advanced reactors as being out of scope (NRC 2014-TN4117). However, if these technologies
should become viable and the NRC reviews one or more license applications for an out of
scope advanced reactor, then the environmental impacts of continued storage of that spent fuel
will be considered in individual licensing proceedings unless the NRC updates NUREG-2157
and the corresponding rule to include the environmental impacts of storing this type of fuel after
a reactor’s licensed life for operation (NRC 2014-TN4117).

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The same requirements for the shipment of spent fuel to and storage at an offsite ISFSI with
respect to NRC and the U.S. Department of Transportation (DOT) regulations would apply to
new reactor SNF. Thus, the analysis of NUREG-2157 (NRC 2014-TN4117) for the safe
handling, storage, and management of SNF could also apply to any type of new reactor SNF,
regardless of its chemical form, and is incorporated here by reference. Several assumptions can
be made simply because any such SNF container (i.e., a storage cask or a transportation
container or cask) or an ISFSI and DTS facilities for new reactor SNF must satisfy the regulatory
requirements of 10 CFR Part 71 (TN301), “Packaging and Transportation of Radioactive
Material,” 10 CFR Part 72 (TN4884), “Licensing Requirements for the Independent Storage of
Spent Fuel, High-Level Radioactive Waste, and Reactor-related Greater Than Class C Waste,”
and 10 CFR Part 73 (TN423), “Physical Protection of Plants and Materials.”

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Any new reactor spent fuel storage or shipping containers must demonstrate that the associated
fuels can always be safely managed (see 10 CFR Part 71 Subpart E (TN301), Package
Approval Standards, for shipping containers and 10 CFR Part 72 Subpart L (TN4884), Approval
of Spent Fuel Storage Casks, for spent fuel storage casks).

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Radionuclide inventories and thermal loading limits should not be a significant departure from
the performance of currently certified spent fuel shipping and storage containers. For example,
the radionuclide inventory and related container shielding for any type of new reactor SNF must
meet the regulatory requirements of 10 CFR 71.47 (TN301), External radiation standards for all
packages and 10 CFR 72.236 (TN4884), Specific requirements for spent fuel storage cask
approval and fabrication.

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If new reactor SNF is not encased in a zirconium alloy, then the highly exothermic chemical
reaction called a runaway zirconium oxidation reaction or autocatalytic ignition as assessed in
NUREG-2157 (NRC 2014-TN4117) is not possible. Metallic fuels could be encased in a type of
stainless steel (e.g., stainless steel [SS] 316, HT9, and D9) rather than a zirconium alloy
cladding (FRWG 2018-TN6696). TRISO fuels are encapsulated in ceramic and carbon-based
materials, and “are structurally more resistant to neutron irradiation, corrosion, oxidation, and
high temperatures (the factors that most impact fuel performance) than traditional reactor fuels”
(DOE 2019-TN6786). Several suitable non-zirconium alloys may exist, including
high-temperature nickel-based alloys and modified Hastelloy N variants, for showing acceptable
compatibility in MSRs (Busby et al. 2019-TN6695).

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In addition, any shipping or storage container for SNF, including SNF from new reactors, would
have to satisfy the regulatory requirements of 10 CFR 71.55 (TN301), “General requirements for
fissile material packages,” and 10 CFR 72.236 (TN4884), “Specific requirements for spent fuel
storage cask approval and fabrication,” which include the following:

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•
•

Confine fuel to a known volume.
Ensure compliance with criticality safety.
Meet specific structural testing requirements.
Permit normal handling and retrieval.

Because the ISFSI infrastructure and the required physical protection is no different for LWR
SNF than for non-LWR SNF, the same considerations provided in NUREG-2157 (NRC 2014TN4117) of a very low probability of an accident or of a successful terrorist attack with the
resulting small environmental risk would apply during continued storage of any new reactor
SNF. The one difference identified in NUREG-2157 was that for non-LWR SNF, the period of
self-protection from acts of terrorism may be shorter than that of LWR SNF, depending on the

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burnup level and the isotopic composition of the SNM (i.e., the attractiveness of the material for
diversion).

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Therefore, if the new reactor SNF conforms with the above analysis for this Category 1 issue,
then the analysis of NUREG-2157 (NRC 2014-TN4117) would bound the environmental impacts
and impacts would be SMALL. The staff relied on the following PPE assumptions to reach this
conclusion:

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• Table S-3 is expected to bound the impacts for new reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:

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Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup
resulting in fewer discharged fuel assemblies to be stored and disposed.

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Less reliance on coal-fired electrical generation plants resulting in less gaseous effluent
releases from electrical generation sources supporting storage and disposal.

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• Waste and spent fuel inventories, as well as their associated certified spent fuel shipping
and storage containers, are not significantly different from what has been considered for
LWR evaluations in NUREG-2157 (NRC 2014-TN4117)

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• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of
Source Material, 10 CFR Part 70 (TN4883), Domestic Licensing of Special Nuclear Material,
10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive Material, 10 CFR
Part 72 (TN4884), Licensing Requirements for the Independent Storage of Spent Fuel,
High-Level Radioactive Waste, and Reactor-related Greater Than Class C Waste, and
10 CFR Part 73 (TN423), Physical Protection of Plants and Materials.

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However, if conditions, such as fuel stability within the uranium spent fuel (ORNL 1970-TN6754,
ORNL 1998-TN6755) and the site conditions for construction and operation of an ISFSI
including fuel transfers, go beyond what is in NUREG-2157, then a project-specific analysis
would be necessary to demonstrate continued safe storage (ORNL 1970-TN6754, ORNL 1998TN6755).

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Disposal of new reactor SNF in a deep geological repository would need to demonstrate
compliance with radiation standards that are expected to be comparable, if not the same, as the
existing radiation standards in Table B-1 in 10 CFR Part 51 (TN250) (e.g., a dose limit of
0.15 millisieverts [15 mrem]). Therefore, the offsite radiological impacts of new reactor SNF
could be expected to be classified as a Category 1 issue with no impact level assigned.

3.14.3 Staff Conclusions about the Environmental Impacts of a New Reactor Fuel Cycle

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It is important to acknowledge that the determinations arrived in this GEIS are based on the
staff’s current understanding of the proposed plans and designs for the activities associated with
new reactor fuel and facilities. The staff reviewed the general literature containing information
about expected new reactor (LWR and non-LWR) fuel cycles. The review examined expected
uranium and uranium-plutonium fuel forms (oxide, metal, TRISO, salt). The staff review
examined available information about uranium extraction, uranium conversion, uranium
enrichment, fuel processing/fabrication, nuclear material transportation, irradiated fuel
processing, spent fuel management, and radioactive waste management as it is related to
expected new reactor systems. The NRC staff assumes that the thorium fuel cycle will not be
significantly different from the uranium fuel cycle, therefore the uranium fuel cycle impacts
should bound the thorium fuel cycle impacts.

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Based on its review of the available, general information, the staff believes that new reactor fuel
cycles will have SMALL environmental impacts (i.e., impacts that are less than or comparable to
those of current LWRs and those discussed in Table S-3), particularly for once-through fuel
cycle options. The lower fuel cycle impacts are the result of improved fuel cycle technologies
(reduced environmental impact), improved reactor technologies, and waste and spent fuel
inventories that are not significantly different from what has been considered for LWR
evaluations (e.g., as in Continued Storage Rulemaking) with respect to hazardous
radionuclides.

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A new reactor applicant would have to demonstrate in its ER that the impacts of its fuel cycle fall
within the values and assumptions of the PPE for the Category 1 issues above (see
Section 1.3.1 of this GEIS). The NRC staff expects the new reactor applicants to describe their
planned fuel cycle designs, plans, and activities. The applicant’s analysis needs to discuss and
analyze any new processes (ones not considered in this NR GEIS) that will be part of their fuel
cycle.

3.15 Transportation of Fuel and Waste

3.15.1 Baseline Conditions and PPE/SPE Values and Assumptions

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The NRC has generically evaluated the environmental effects of the transportation of fuel and
waste to and from LWRs in 10 CFR 51.52 Table S-4, Environmental effects of transportation of
fuel and waste (TN250). However, the environmental data in Table S-4 is only applicable to
LWRs that use uranium oxide, or UO 2, fuel that meets specific criteria in 10 CFR 51.52(a) as
expanded in Addendum 1 of NUREG-1437, Generic Environmental Impact Statement for
License Renewal of Nuclear Plants Addendum to Main Report (NRC 1999-TN289) and as
discussed in Revision 2 of NUREG-1437, Generic Environmental Impact Statement for License
Renewal of Nuclear Plants (NRC 2024-TN10161). Some new reactor developers are expected
to use uranium fuel with enrichment levels of up to 20 percent enrichment, known as HALEU. In
addition, as discussed in Section 3.14 of this GEIS, 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 new reactors based on a Th-232/U-233 fuel cycle. While Table S-4
does not apply to new reactors and non-UO2 fuels, the transportation of fuel and waste is a
connected action under NEPA regulations, guidance, and case law. Therefore, the NRC must
still evaluate transportation impacts for the non-LWR fuel and waste to meet its obligations
under NEPA as has been done for large LWR UO2 fuels. This section addresses both the
radiological and nonradiological environmental impacts from incident-free and accident
conditions resulting from (1) shipment of unirradiated fuel to the new 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. Air emissions from the transportation
of fuel and waste, specifically for greenhouse gases or GHGs, are discussed in Section 3.3 of
this GEIS.

3.15.1.1

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The NRC performed a generic analysis of the environmental effects of the transportation of fuel
and waste to and from LWRs in the Environmental Survey of Transportation of Radioactive
Materials To and From Nuclear Power Plants, WASH-1238 (AEC 1972-TN22) and in a
supplement to WASH-1238, NUREG-75/038 (NRC 1975-TN216), and found the impact to be
small. These documents provided the basis for Table S-4 in 10 CFR 51.52 (TN250) that
summarizes the environmental impacts of transportation of fuel and waste to and from one LWR

Table S-4 on the Transportation of Fuel and Waste

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of 3,000 to 5,000 MW(t) (1,000 to 1,500 MW(e)). Impacts are provided for normal conditions of
transport and accidents in transport for a reference 1,100 MW(e) LWR.29 Dose to transportation
workers during normal transportation operations was estimated to result in a collective dose of
4 person-rem per RRY. The combined dose to the public along the route and the dose to
onlookers were estimated to result in a collective dose of 3 person-rem per RRY.

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Based on public comments on the 1996 version of NUREG-1437 (NRC 1996-TN288), the NRC
reevaluated the transportation issues and the adequacy of Table S-4 for license renewal
application reviews. In 1999, the NRC issued an addendum to the 1996 License Renewal GEIS
(NRC 1999-TN289) in which the agency evaluated the applicability of Table S-4 to future license
renewal proceedings, given that the spent fuel is likely to be shipped to a single repository (as
opposed to several destinations, as originally assumed in the preparation of Table S-4) and
given that shipments of spent fuel are likely to involve more highly enriched fresh fuel (more
than 4 percent as assumed in Table S-4) and higher-burnup spent fuel (higher than
33,000 MWd/MTU as assumed in Table S-4). In the addendum, the NRC evaluated the impacts
of transporting the spent fuel from reactor sites to the candidate repository at Yucca Mountain
and the impacts of shipping more highly enriched fresh fuel and higher-burnup spent fuel. On
the basis of the evaluations, the NRC concluded that the values given in Table S-4 would still be
bounding, as long as the (1) enrichment of the fresh fuel was 5 percent or less, (2) burnup of the
spent fuel was 62,000 MWd/MTU or less, and (3) higher-burnup spent fuel (higher than
33,000 MWd/MTU) was cooled for at least 5 years before being shipped offsite. A later study
found that the impacts presented in Table S-4 would bound the potential environmental impacts
that would be associated with transportation of SNF with up to 75,000 MWd/MTU burnup,
provided that the fuel is cooled for at least 5 years before shipment (Ramsdell et al. 2001TN4545).

3.15.1.2

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Since the publication of WASH-1238 (AEC 1972-TN22) and NUREG-75/038 (NRC 1975TN216), the NRC has undertaken four studies regarding the risk from the transportation of SNF.
Each study improved upon the assumptions and analysis techniques from the prior study for
assessing these risks.

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In September 1977, the NRC published NUREG-0170, Final Environmental Statement on the
Transportation of Radioactive Material by Air and Other Modes, which assessed the adequacy
of the regulations in 10 CFR Part 71 (TN301), then entitled Packaging and Transportation of
Radioactive Waste (NRC 1977-TN417, NRC 1977-TN6497). In that assessment, the measure
of safety was the risk associated with radiation doses to the public under routine and accident
transport conditions, and the risk was found to be acceptable. Since that time, there have been
two affirmations of this conclusion for SNF transportation, each using improved tools and
information.

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A 1987 study applied actual accident statistics to projected spent fuel transportation (Fischer
et al. 1987-TN4105). This study, known as the “Modal Study,” recognized that accidents could
be described in terms of the strains they produced in transportation packages (for impacts) and
the increase in package temperature (for fires). Like NUREG-0170 (NRC 1977-TN417,
NRC 1977-TN6497), the 1987 study based risk estimates on models because the limited
number of accidents that had occurred involving spent fuel shipments was not sufficient to

Additional NRC Studies of the Risk from the Transportation of SNF

Note that the basis for Table S-4 is a 1,100 MW(e) LWR at an 80 percent capacity factor (AEC 1972TN22; NRC 1975-TN216).

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support projections or predictions. The Modal Study’s refinement of modeling techniques and
use of accident frequency data resulted in smaller assessed risks than had been projected in
NUREG-0170.

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In 2000, a study of two generic truck packages and two generic rail packages analyzed the
package structures and response to accidents by using computer modeling techniques
(Sprung et al. 2000-TN222). The study used semi-trailer truck and rail accident statistics for
general freight shipments because, even though more than 1,000 spent fuel shipments had
been completed in the United States by the year 2000 and many thousands more had been
completed safely internationally, there had been too few accidents involving spent fuel
shipments to provide statistically valid accident rates. Sprung et al. 2000 (TN222) used
improved technology to analyze the ability of containers to withstand an accident. This study
concluded that the risk from the increased number of spent fuel shipments that could occur in
the first half of this century would be even smaller than originally estimated in NUREG-0170
(NRC 1977-TN417, NRC 1977-TN6497).

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NUREG-2125, published in January 2014, presented the results of a fourth investigation into the
safety of SNF transportation (NRC 2014-TN3231). The selected routes included the origins and
destinations analyzed in NUREG/CR-6672 (Sprung et al. 2000-TN222), thereby permitting the
results of the studies to be compared. This investigation showed that the risk from the radiation
emitted from the packages is a small fraction of naturally occurring background radiation and
the risk from accidental release of radioactive material is several orders of magnitude less.
Because there have been only minor changes to the radioactive material transportation
regulations in NUREG-0170 (NRC 1977-TN417, NRC 1977-TN6497) and NUREG-2125, the
calculated dose from the external radiation from the package under routine transport conditions
is similar to what was found in earlier studies. The improved analysis tools and techniques,
improved data availability, and a reduction in uncertainty have made the estimate of accident
risk from the release of radioactive material in NUREG-2125 approximately five orders of
magnitude less than what was estimated in NUREG-0170. The results from NUREG-2125 (NRC
2014-TN3231) demonstrate that NRC regulations continue to provide adequate protection of
public health and safety during the transportation of SNF.

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The NRC published NUREG-2266, “Environmental Evaluation of Accident Tolerant Fuels with
Increased Enrichment and Higher Burnup Levels,” in July 2024 to support efficient and effective
licensing reviews of ATFs and to reduce the need for a complex site-specific environmental
review for each ATF LAR (NRC 2024-TN10333). NUREG-2266 evaluated the reasonably
foreseeable impacts of near-term ATF technologies with increased enrichment and higher
burnup levels on the uranium fuel cycle, transportation of fuel and waste, and decommissioning
for LWRs (i.e., a bounding analysis). To this end, the NRC staff assessed and applied available
near-term ATF technology performance analyses, data, and studies; information from prior NRC
environmental analyses; and the assessment of other publicly available data sources and
studies to complete an evaluation of ATF with increased enrichment and higher burnup levels.
Based on the evaluations in this study, the NRC staff determined that Table S-4 of 10 CFR
51.52(c) would bound the deployment and use of near-term ATF for up to 8 wt% U-235 and
80 GWd/MTU average assembly burnup. This study also indicates there would be no significant
adverse environmental impacts for the uranium fuel cycle, transportation of fuel and wastes, and
decommissioning associated with deploying near-term ATF.

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For the assessment of the potential generic impacts of transporting SNF in this GEIS,
NUREG-2125 (NRC 2014-TN3231) is examined for environmental impacts because it is the
most recent study that applies the latest knowledge and analytical tools.

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3.15.1.3

Additional NRC Information Sources

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Several NRC EISs regarding the construction and operation of new reactors contain an analysis
of the potential environmental impacts due to the transportation of LWR fuel and waste. These
transportation assessments were performed by the new reactor applicants to meet the
regulatory requirements of 10 CFR 51.52 (TN250). The NRC staff then reviewed the applicant’s
analyses and made a final assessment of the impacts, normalized with respect to power level
and the amount of radioactive material per shipment, to allow for comparison to the results
presented in Table S-4 of 10 CFR 51.52. While 10 CFR 51.52 applies only to LWRs, these
assessments may help inform the staff’s assessment in this GEIS because of the similarities in
transportation modes (e.g., packaging, routing, and distances) and the quantities of radioactive
material per shipment.

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In addition to the new reactor EISs, the NRC has published two EISs regarding the proposed
licensing of two interim storage facilities (NRC 2021-TN10124, NRC 2022-TN10171). The
transportation assessments of these EISs will also be examined for informing the transportation
assessments in this GEIS.

3.15.1.4

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The DOE routinely ships radioactive material between their various national laboratories and
other nuclear facilities. Examples of these shipments include shipments of LLRW and
transuranic wastes to DOE disposal sites at the Nevada Test Site and the Waste Isolation Pilot
Plant, respectively. Some DOE LLRW has also been shipped to commercial disposal sites.
DOE has also transported SNF as part of various national programs, such as shipments of
research quantities of commercial SNF to the INL (INL 2020-TN6500). Hence, DOE developed
a transportation risk assessment handbook to provide a methodology for DOE staff and DOE
contractors to apply when conducting necessary NEPA analysis related to DOE programs
involving shipments of radioactive material (DOE 2002-TN1236). The methodology presented in
the DOE handbook is the preferred analytical method for assessing the environmental impacts
of the transportation of fuel and waste.

28
29
30
31
32
33
34
35
36
37
38
39

DOE has also published a number of reports that include transportation risk assessments as a
component of their NEPA analysis in support of a number of DOE program decisions. A majority
of these are for specific situations and for a limited number of radioactive material shipments.
There are two transportation risk assessments that are more comprehensive with respect to
potentially large shipping campaigns. The first of these two assessments is the transportation
analysis in support of the licensing of the Yucca Mountain geologic repository (DOE 2002TN1236). The second study is a series of reports (Monette et al. 1995-TN6505, Monette et al.
1995-TN6506; Biwer et al. 1996-TN6502; Monette et al. 1996-TN6501, Monette et al. 1996TN6503) concerning the transportation of radioactive wastes as part of the production of the
DOE Waste Management Programmatic Environmental Impact Statement (DOE 1997-TN6752).
Information from these assessments will be used in this evaluation of the environmental impacts
of non-LWR waste shipments.

3.15.1.5

41
42
43
44

There is limited information regarding the transportation of several forms of non-LWR fuel due to
the expected higher enrichment levels (i.e., HALEU fuel) and the physical form of the non-LWR
fuel being shipped. This limited information has been identified in several reports and
conference/seminar/workshop presentations and principally involves suitable transportation

U.S. Department of Energy Transportation Risk Assessments

Issues for the Transportation of Non-LWR Fuel and Wastes

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2

packages to support the economic use of HALEU materials (Jarrell 2018-TN6508; Eidelpes
et al. 2019-TN6507; Reardon et al. 2019-TN6952).

3
4
5

Principal issues involve the lack of certified transport packages for unirradiated and irradiated
HALEU fuel and radioactive waste. Items being considered for non-LWR fuel and waste
transport packages include the following:

• non-LWR fresh fuel shipments likely to be similar to those for LWRs (except for molten salt);

7
8

• processing operations and transportation for MSRs and sodium fast reactors are
significantly different than for the current reactor fleet; and

• uncertainty in the post irradiation forms for transport and storage.

10
11
12
13
14
15
16
17

Another potential departure from current transportation practices for LWR unirradiated, or fresh,
fuel and SNF is the fuel loading in one transport package. Currently, multiple shipments must be
made to fuel the LWR core and to remove the SNF from the LWR site. There are non-LWR
developers whose relatively small size of the reactor core may lead them to consider
transporting the entire and completely assembled reactor core or reactor vessel with the core to
and from the reactor site. These are all factors that must be considered in this evaluation to
determine if the environmental impacts from the transportation of non-LWR fuel and waste can
be generically addressed.

3.15.1.6

19
20
21
22
23
24
25

The effects of incident-free and accident transportation are proportional to the total shipment
distance associated with the unirradiated fuel, radioactive waste, or irradiated fuel, i.e., as the
number of shipments and the shipping distance increase, the effects from transporting the
unirradiated fuel, radioactive waste, or irradiated fuel also increase. For this reason, the total
shipment distance was used as the metric for the transportation PPE. The total shipment
distance is quantified in terms of the annual one-way shipment distance or the annual round-trip
shipment distance.

The annual one-way shipment distance is calculated using the formula:

27
28

Development of the Transportation Plant Parameter Envelope

• Annual One-Way Shipment Distance (km) = Annual Number of Normalized Shipments ×
One-Way Shipping Distance (km)

• The annual round-trip shipment distance is calculated using the formula:

30
31

• Annual Round-Trip Shipment Distance (km) = 2 × Annual Number of Normalized
Shipments ×

One-Way Shipping Distance (km)

33
34
35
36
37

In order to develop the transportation PPE, NRC staff examined WASH-1238 and past new
reactor EISs to determine the total shipment distances evaluated in these EISs for unirradiated
fuel, radioactive waste, or irradiated fuel. The NRC staff also identified factors that could affect
the relationship between the effects of incident-free and accident transportation and the total
shipment distance.

Factors identified by the NRC staff included:

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2
3
4
5
6
7
8
9
10
11
12

• The use of different versions of RADTRAN to estimate the effects of transporting
unirradiated fuel, radioactive waste, and irradiated fuel: The radiation doses and risks
discussed in Sections 3.15.1.7, 3.15.1.8, and 3.15.1.9 below were estimated using the
RADTRAN computer code. RADTRAN has changed over time, with Version 5 (Neuhauser
et al. 2000-TN6990; Neuhauser and Kanipe 2003-TN6989) being used in EISs published in
the period 2006-2008, Version 5.6 (Weiner et al. 2008-TN302) being used in EISs published
in the period 2011-2016, and Version 6 being the current version (Weiner et al. 2013TN3390, Weiner et al. 2014-TN3389). A specific example of how RADTRAN has changed
over time is in how it estimates long-term doses after a transportation accident, where
RADTRAN 5 and 5.6 estimated a 50-year long-term dose from transportation accidents,
while RADTRAN 6 no longer provides 50-year long-term dose estimates (see page 66 and
equation 75 in Weiner et al. 2014-TN3389).

13
14
15
16
17
18
19

• The use of different census data to estimate the effects of transporting unirradiated fuel,
radioactive waste, and irradiated fuel: The radiation doses and risks discussed in
Sections 3.15.1.7, 3.15.1.8, and 3.15.1.9 below were estimated using 2000 census and
2010 census data; earlier EISs used 2000 census data and later EISs used 2010 census
data to estimate transportation impacts. The use of different census data can affect the
estimates of the effects of transporting unirradiated fuel, radioactive waste, and irradiated
fuel for a transportation route, even if the route remains the same.

20
21
22
23
24
25
26
27

• The use of different sources of transportation accident, injury, and fatality rate data to
estimate the effects of transporting unirradiated fuel, radioactive waste, and irradiated fuel:
In general, the radiological and nonradiological effects discussed in Sections 3.15.1.7,
3.15.1.8, and 3.15.1.9 below were estimated using state-level accident, injury, and fatality
rate data from Saricks and Tompkins (1999-TN81). However, other sources of transportation
accident, injury, and fatality rate data have been used (e.g., DOT 2013-TN3930). The use of
different accident, injury, and fatality rate data can affect the estimates of the effects of
transporting unirradiated fuel, radioactive waste, and irradiated fuel.

28
29
30
31
32
33

• The number of exposed persons along different transportation routes: Lower transportation
effects would be estimated for routes through more sparsely populated areas (rural) than for
routes through more highly populated areas (urban and suburban), where higher
transportation effects would be estimated. The fraction of a route that is urban, suburban,
and rural will vary for the same destination depending on the originating site’s location and
on the states traversed by a transportation route.

34
35
36
37
38
39

• Differences in the accident, injury, and fatality rates in the various states traversed by a
transportation route: The transportation accident effects discussed in Sections 3.15.1.7,
3.15.1.8, and 3.15.1.9 below were typically estimated using state-level accident, injury, and
fatality rate data (see Saricks and Tompkins 1999-TN81). These rates differ by state, which
can yield higher or lower estimates of effects depending on the states traversed by a
transportation route.

40
41
42
43
44
45
46

• Differences in parameters such as source-to-receptor distances, shielding factors,
transportation cask dimensions, etc. used to estimate the effects of transporting unirradiated
fuel, radioactive waste, and irradiated fuel: The radiological effects discussed in
Sections 3.15.1.7, 3.15.1.8, and 3.15.1.9 below were estimated using specific values of
parameters deemed appropriate at the time of the analysis, such as source-to-receptor
distances, shielding factors, and transportation cask dimensions. These specific parameter
values would affect the calculated values in the tables below.

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1
2
3
4
5
6
7

• Differences in the radionuclide inventory contained in a transportation cask due to the
irradiated fuel having higher or lower burnup: The radiological effects associated with
transportation accidents involving irradiated fuel discussed in Section 3.15.1.9 were
estimated using a transportation cask with a capacity of 0.5 MTU. However, the burnup
associated with the irradiated fuel would be reactor-specific. The burnup affects the
radionuclide inventory, which in turn affects the estimates of the estimated radiation doses
from transportation accidents involving irradiated fuel.

8
9
10
11
12
13
14

• Use of an updated stop model for unirradiated fuel shipments: The transportation effects in
the North Anna (NRC 2006-TN7), Clinton (NRC 2006-TN672), and Grand Gulf (NRC 2006TN674) EISs were estimated using a stop model with a population density of
64,300 people/km2 in a 1 to 10 m annular ring around the vehicle. In addition, the exposure
time was estimated to be 4.5 hours and no shielding was assumed. In later EISs,
transportation effects were estimated using the updated stop model described by
Griego et al. (1996-TN69).

15
16
17

NRC staff found that these factors do not affect the use of the total shipment distance as the
metric for the transportation PPE but account for the variations in the calculated values in the
subsequent tables.

3.15.1.7

19
20
21
22
23
24
25
26
27
28
29
30

Unirradiated nuclear fuel assemblies, or fresh fuel elements, are transported to the nuclear
reactor in protective outer packages designed to prevent damage to the fuel elements in transit
(Rhoads 1977-TN6572). Typically, one pressurized water reactor (PWR) or two boiling water
reactor fuel elements are placed in a protective overpack designed to protect the valuable fuel
element from damage during transport (NRC 2019-TN6511, NRC 2019-TN6512, NRC 2019TN6513). These overpacks are usually shipped to the nuclear reactor site by truck. Ten
containers of PWR fuel (Table B-2 of WEC 2019-TN6510) each containing one assembly or six
containers of boiling water reactor fuel each containing two assemblies are typically placed on a
standard truck semi-trailer with a current maximum Federal gross vehicle weight limit of
80,000 pounds (DOT 2015-TN6753).30 The overpack dimensions appear to be the limiting factor
for the number of overpacks in one shipment and not the maximum Federal gross vehicle
weight limit.

31
32
33
34
35
36
37
38
39
40
41
42
43

The necessary NRC-certified transport packages for unirradiated new reactor fuel at HALEU
enrichment levels are being developed (Jarrell 2018-TN6508; Eidelpes et al. 2019-TN6507;
Jarrell and Eidelpes 2020-TN6694). For example, in Section 4, Review and Application of
Existing Packaging Designs, in the paper by Eidelpes et al. (2019-TN6507), the authors note
that two promising packaging designs were identified that could be adapted for HALEU
transportation, and could be readily transported by truck. These are the Transnuclear Americas
Long Cask (TN-LC) (NRC 2017-TN6684) and the NAC International Inc. (NAC) International
Optimal Modular Universal Shipping for low-activity contents (OPTIMUS™-L) packaging. In
addition, review of the NRC-certified transport packages listed on DOE’s Radioactive Material
Packaging website reveals a small number of transportation packages that are currently
certified for shipping HALEU material, such as the VP-55 package (Hennebach and Langston
2020-TN6693; NRC 2020-TN6686). The VP-55 package is also certified for various forms of
unirradiated TRISO fuel in the form of uranium kernels and TRISO particles, which may be

Transportation of Unirradiated New Reactor Fuel

10 CFR 51.52 (TN250) Table S–4 includes a condition that the truck shipments not exceed 73,000 lb
as governed by Federal or State gross vehicle weight restrictions.

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1
2

loose or mixed in a graphite matrix and pressed into compacts of various fuel forms
(e.g., annular cylinders, planks, right circular cylinders, spheres, etc.).

3
4
5
6
7
8

There are also DOE-certified transport packages that potentially could be applied for shipping
HALEU fuel (Jarrell 2018-TN6508). The higher enriched material approved for such certified
packages could be in the form of UF6, TRISO, and research reactor plate fuel. Given the nature
of liquid-fueled MSRs where the HALEU material is mixed with the chloride- or fluoride-based
molten salt, it should be expected that the HALEU material would be shipped from the
enrichment site to the MSR site in the form of UF6 (McFarlane et al. 2019-TN6741).

3.15.1.7.1 Normal Conditions

10
11
12
13
14
15
16
17
18

Normal conditions, sometimes referred to as “incident-free” transportation, are transportation
activities during which shipments reach their destination without releasing any radioactive
material to the environment (i.e., not being involved in a vehicular accident). Impacts from these
shipments would be from the low levels of radiation that penetrate the shielding provided by
unirradiated fuel shipping containers. In the case of unirradiated fuel, the radiation would be
from the natural decay of the uranium isotopes. Past studies have determined the largest
impacts would occur for shipments made by trucks due to a larger number of shipments that
would occur versus rail shipments, and these impacts would also have a larger exposure
population due to existing travel densities on U.S. roadways.

19
20
21
22
23
24
25
26
27
28
29
30
31

The number of unirradiated fuel shipments for WASH-1238 (AEC 1972-TN22) and new reactor
LWR licensing actions are provided in Table 3-10. This table is broken down by shipments for
an initial core loading, the number of annual shipments to support core reloading, and the total
number of shipments over the lifetime of the operating license (assumed to be 40 years). For
example, the Advanced Passive 1000 (AP1000) fuel shipments would have approximately
seven PWR overpacks for each truck shipment.31 This results in a mass loading of
approximately 3.8 MTU per truck shipment. It is anticipated that for an MSR, unirradiated fuel
would be shipped in the form of UF6. For low-enriched UF6, a standard truck loading is six
Type 30B cylinders per truck (USEC 1999-TN6515) for approximately 9.3 MTU per truck. To
have the equivalent MTU as the PWR unirradiated fuel shipment would require about three
Type 30B cylinders per truck. Assuming equal uranium requirements, this would reduce the
number of unirradiated fuel shipments required for an MSR by about 50 percent compared to a
large LWR.

32
33
34
35
36
37
38
39
40
41

The radiological impacts provided in WASH-1238 (AEC 1972-TN22) and the previous new
reactor EISs, as shown in Table 3-11, were based on annual exposures from the expected
number of shipments over a year as normalized to 1,100 MW(e) (or 880 MW(e) net electrical
output). Another factor to consider when extending this analysis to new reactors is the
assumption applied in WASH-1238 and in the staff’s analysis of new reactor unirradiated fuel
shipments that the radiation dose rate at 3.3 ft from the transport vehicle is about 0.1 mrem/hr.
This assumption should also be reasonable for new reactors that use HALEU fuel because the
HALEU materials would still be low-dose-rate uranium radionuclides and would likely be
packaged similarly to those described in WASH-1238 (i.e., inside a metal container that
provides little radiation shielding).

There are 157 fuel assemblies per core loading and 23 initial core loading shipments; therefore, 157/23
≈ 6.8 rounded to 7 fuel assemblies per shipment.

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2

Table 3-10

Number of Truck Shipments and One-Way Shipping Distances for
Unirradiated Fuel
Number of Number of Number of Number of Number of
Shipments Shipments Shipments Shipments Shipments
Per Site
Per Site
Per Site
Per Site
Per Site
One-Way
Normalized Shipping
Annual
Distance
Shipments(b)
(km)

Initial
Core

Total
Reload(a)

Total(a)

WASH-1238 (NRC 2006-TN7)

234

252

6.3

3,200

North Anna Power Station Unit 3 ESP
(NRC 2006-TN7)

780

831

18.2

3,200

Clinton Exelon ESP (NRC 2006-TN672)

780

831

18.2

3,200

Grand Gulf ESP (NRC 2006-TN674)

780

831

18.2

3,200

Vogtle Units 3 and 4 ESP (NRC 2008TN673)

210

233

3,200

Calvert Cliffs Unit 3 COL (NRC 2011TN1980)

298

4.4

3,200

South Texas Units 3 and 4 COL (NRC
2011-TN1722)

372

6.6

3,200

Virgil C. Summer Units 2 and 3 COL
(NRC 2011-TN1723)

233

3,200

Levy Units 1 and 2 COL (NRC 2012TN1976)

210

233

1,166

100

1.5

3,200

Enrico Fermi Unit 3 COL (NRC 2013TN6436)

323

361

5.3

3,600

William States Lee Units 1 and 2 COL
(NRC 2013-TN6435)

234

257

6.1

3,200

PSEG ESP (NRC 2015-TN6438)

300

345

4.9

4,400

Turkey Point Units 6 and 7 COL (NRC
2016-TN6434)

209

3,200

Bell Bend COL (NRC and USACE 2016TN6562)

298

4.3

4,247

456

492

3,944

5,129

Site Name

Comanche Peak Units 3 and 4 COL
(NRC 2011-TN6437)

Clinch River ESP (NRC 2019-TN6136)
NUREG-2266 (NRC 2024-TN10333)
(a)
(b)
(c)

Total shipments of unirradiated fuel over a 40-year plant lifetime.
Normalized to Reference LWR (880 MW(e) net).
Largest annual impact for an existing LWR from NUREG-2266 Table 3-6 (NRC 2024-TN10333).

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2

Table 3-11

Radiological Impacts Under Normal Conditions of Transporting Unirradiated
Fuel from WASH-1238 and New Reactor Sites

Site Name
WASH-1238 (NRC 2006-TN7)
North Anna Power Station Unit 3 ESP (NRC
2006-TN7)
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
Vogtle Units 3 and 4 ESP (NRC 2008-TN673)
Calvert Cliffs Unit 3 COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC
2011-TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC
2011-TN6437)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC
2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016TN6434)
Bell Bend COL (NRC and USACE 2016TN6562)
Clinch River ESP (NRC 2019-TN6136)
NUREG-2266 (NRC 2024-TN10333) (c)
Maximum Estimate
(a)
(b)
(c)

3
4
5
6

Annual
Total OneWay
Shipment
Distance(a)
(km)
20,160
58,240

Population
Impacts
(personrem/yr)(b)
Workers
0.011
0.031

Population
Impacts
(personrem/yr)(b)

Public
Onlookers
0.042
0.12

Population
Impacts
(personrem/yr)(b)
Public
Along Route
0.0010
0.0029

58,240
58,240
16,000
14,080
21,120

0.031
0.031
0.0085
0.0076
0.011

0.12
0.12
0.015
0.016
0.024

0.0029
0.0029
0.00021
0.00023
0.00033

16,000

0.0085

0.018

0.00025

5,830
4,800

0.0031
0.0041

0.0076
0.0071

0.00029
0.000043

19,080
19,520

0.010
0.012

0.018
0.021

0.00018
0.00029

21,560
16,000

0.0071
0.0090

0.016
0.018

0.00047
0.00025

18,262

0.0098

0.038

0.00067

59,160
25,645
59,160

0.0078
0.0634
0.0634

0.044
0.340
0.340

0.0012
0.0013
0.0029

The total shipment distance is based on the number of annual shipments multiplied by the shipping distance.
Normalized to Reference LWR (880 MW(e) net).
Largest annual impact for an existing LWR from NUREG-2266 Table 3-6 (NRC 2024-TN10333).

The one-way distances should also be bounding for unirradiated HALEU fuel shipments
because the existing fuel fabrication facility locations would still be expected to fabricate HALEU
fuel. Additionally, the distances from enrichment facilities to an MSR site for HALEU UF 6
shipments should also be within these one-way distances.

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3.15.1.7.2 Transportation Accidents

2
3
4
5
6
7
8
9
10
11

Accident risks are a combination of accident frequency and consequence. Accident frequencies
for transportation of unirradiated fuel are expected to be lower than those used in the analysis in
WASH-1238 (AEC 1972-TN22). This is based on the NRC staff evaluations in previous new
reactor EISs where the NRC staff identified the trends in improvements in highway safety and
security, and an overall reduction in traffic accident, injury, and fatality rates since WASH-1238
was published. Although packages for all types of new reactor unirradiated fuel have not been
designed or certified by the NRC, these packages must comply with the packaging
requirements contained in 10 CFR Part 71 (TN301) and, for this reason, the impacts of
radiological accidents during transport of unirradiated fuel to a new reactor are expected to be
smaller than those listed in Table S-4 in 10 CFR 51.52 (TN250).

12
13
14
15
16
17
18
19
20
21

Nonradiological impacts are the human health impacts projected to result from traffic accidents
involving shipments of unirradiated fuel to the new reactor site (i.e., the analysis does not
consider the radiological or hazardous characteristics of the cargo). Nonradiological impacts
include the projected number of traffic accidents, injuries, and fatalities that could result from
shipments of unirradiated fuel to the site and return shipments of empty containers from the site.
The methodology for determining the nonradiological impacts can be found in any of the new
reactor EISs, such as in Section 6.2.1.3, Nonradiological Impacts of Transportation Accidents,
of the Clinch River ESP Final EIS (NRC 2019-TN6136). This methodology is incorporated by
reference in this GEIS. The nonradiological impacts for unirradiated fuel shipment accidents
from WASH-1238 (AEC 1972-TN22) and the new reactor EISs are provided in Table 3-12.

3.15.1.7.3 Summary of PPE Values for Transport of Unirradiated New Reactor Fuel

23
24

Based on the above information, Table 3-11 and Table 3-12 present the PPE for transport of
unirradiated new reactor fuel. This PPE consists of two components:

25
26
27
28

• The maximum annual one-way shipment distance (59,160 km) presented below in
Table 3-11. The annual shipments associated with the one-way shipment distance have
been normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an
80 percent capacity factor from WASH-1238.

29
30
31
32

• The maximum annual round-trip shipment distance (118,320 km) presented below in
Table 3-12. The annual shipments associated with the round-trip shipment distance have
been normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an
80 percent capacity factor from WASH-1238.

33
34
35
36
37
38
39
40

The PPE applies to situations where the enrichment of the unirradiated new reactor fuel is
20 percent or less, based on the unlimited A 2 value in Table A-1 in 10 CFR Part 71 for
unirradiated uranium enriched to 20 percent or less (10 CFR Part 71-TN301). This PPE does
not apply to situations in which a new reactor applicant proposes to ship the unirradiated reactor
fuel by air, ship, or barge; or in which a new reactor applicant proposes that an unirradiated fuel
transportation package for the new reactor be approved using the provisions of 10 CFR 71.12,
10 CFR 71.41(c), or 10 CFR 71.41(d), such as might be applied for when shipping a complete
unirradiated reactor core.

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Table 3-12

Nonradiological Impacts of Transporting Unirradiated Fuel

Annual Total
Round-Trip
Shipment
Distance(a)
(km)
40,320
116,480

Accidents
per Year(b)
-(c)
-(c)

Injuries
per
Year(b)
-(c)
-(c)

Fatalities
per
Year(b)
-(c)
-(c)

116,480
116,480
32,000
28,160
42,240

-(c)
-(c)
0.0090
0.013
0.020

-(c)
-(c)
0.0061
0.0066
0.0098

-(c)
-(c)
0.00029
0.00041
0.00061

32,000

0.015

0.0074

0.00046

11,660
9,600

0.0069
0.0026

0.0038
0.0013

0.00031
0.000087

38,160
39,040

0.018
0.018

0.0089
0.0090

0.00055
0.00056

43,120
32,000

0.024
0.015

0.012
0.0074

0.00072
0.00046

36,524

0.14

0.0086

0.00030

0.069
0.0138
0.14

0.035
0.00534
0.035

0.0018
0.00046
0.0018

118,320
51,290
118,320

(a) The total shipment distance is based on the number of annual shipments multiplied by the round-trip shipping
distance. The round-trip distance is used because nonradiological vehicle accident impacts could occur on the
return trip.
(b) Normalized to Reference LWR (880 MW(e) net).
(c) Not analyzed.
Largest annual impact for an existing LWR from NUREG-2266 Table 3-8 (NRC 2024-TN10333).

2
3
4
5
6
7
8
9
10

3.15.1.8

Transportation of Radioactive Waste from New Reactors

As discussed in Section 3.10 of this GEIS, radioactive waste can consist of a variety of
materials with radioactivity levels from just above background radiation levels found in nature to
very high radioactivity in certain cases. While SNF is also radioactive waste, it is classified as
high-level radioactive waste, or HLW, and will be discussed in Section 3.15.1.8. This section
assesses the LLRW generated at a new reactor site that would be stored onsite, either until it
has decayed away and can be disposed of as ordinary trash, or until amounts are large enough
for shipment to a LLRW disposal site in packages authorized by the DOT (e.g., Type A
packages) or approved by the NRC (e.g., Type B transport packages).

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2
3
4
5

The characteristics of radioactive waste from new reactors are expected to be the same as
those of the radioactive waste generated by the current LWR fleet. Because of the design, size,
and the nature of the potential operations at a new reactor, the amount of LLRW likely to be
generated annually by a new reactor could be noticeably less than that generated by the current
LWRs.

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

The staff has assessed LLRW shipment impacts as part of the environmental review of new
reactor ESP and COL applications relative to the annual LLRW shipments shown in Table 3-13.
As noted on the NRC website for LLRW disposal (NRC 2020-TN6516), there are four existing
commercial LLRW disposal facilities in the United States that accept various classes of LLRW. 32
All are in Agreement States. The Low-Level Radioactive Waste Policy Amendments Act of 1985
(Public Law 99–240, 99 Stat. 1842; TN6517) gave the States responsibility for the disposal of
their LLRW. The Act encouraged the States to enter into compacts that would allow them to
dispose of waste at a common disposal facility. Two LLRW disposal facilities only accept wastes
from within their Compact. Two other LLRW disposal facilities could accept LLRW regardless of
the location of the LLRW generator. One LLRW disposal site will accept Class A LLRW and
another LLRW disposal site will accept Class A, B, and C LLRW. EnergySolutions Clive
Operations, located in Clive, Utah, accepts waste from all regions of the United States. Clive is
licensed by the State of Utah for Class A waste only (NRC 2017-TN6518). WCS, LLC, located
near Andrews, Texas, accepts waste from the Texas Compact generators and outside
generators with permission from the Compact. WCS is licensed by the State of Texas to
dispose of Class A, B, and C waste. For the new reactor LLRW transportation impacts, the staff
selected the EnergySolutions or the WCS LLRW disposal facility if the location was not in a
Compact with one of the other two LLRW disposal facilities.

24
25
26
27
28
29
30

The DOE’s Manifest Information Management System (MIMS) is a database used to monitor
the management of commercial LLRW in the United States (DOE 2024-TN10120). The LLRW
information in MIMS is derived from manifests for waste shipments to one closed and four
operating commercial LLRW disposal facilities. MIMS information for the most recent five years
for available data (i.e., 2019 to 2023) was compiled for the four commercial LLRW disposal
facilities by the different classes of LLRW. Table 3-14 provides the breakdown to each LLRW
disposal facility by volume and Table 3-15 does so by activity.

31
32
33
34

As can be seen in a comparison of annual waste volumes in Table 3-13 and Table 3-14, all of
the LWR waste streams are a small fraction of the median annual total volumes for the last
5 years of data. The annual curie content of the LLRW from new reactors is also expected to be
small fraction of the median annual total as provided in Table 3-15.

The classes of LLRW are defined under 10 CFR 61.55, “Waste classification” (10 CFR Part 61-TN252).

3-188

1
2

Table 3-13

Summary of Radioactive Waste Shipments and One-Way Shipping
Distances

Site Name
WASH-1238 (NRC 2006-TN7)
North Anna Power Station Unit 3 ESP (NRC
2006-TN7)
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
Vogtle Units 3 and 4 ESP (NRC 2008-TN673)
Calvert Cliffs COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011TN6437)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC
2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016TN6434)
Bell Bend COL (NRC and USACE 2016TN6562)
Clinch River ESP (NRC 2019-TN6136)

Annual Waste
Generation per
Unit (m3/yr-unit)
108
168

Number of
Radioactive
Waste
Shipments(a)
46
51

One-Way
Shipping
Distance (km)
-(b)
-(b)

168
168
56
208
99

51
51
21
9
31

-(b)
-(b)
800
800
800

800

56
433

21
109

800
800

449
56

114
21

800
800

432.7
56

105.4
23

1110
800

208

800

142

1954.3

(a) The number of shipments was calculated assuming the average waste shipment capacity of 2.34 m 3 (82.6ft3) per
shipment applied in WASH-1238 (AEC 1972-TN22) (108 m3/yr divided by 46 shipments/year yields 2.34 m3 per
shipment). The number of shipments was also normalized to 880 MW(e).
(b) Not analyzed.

3-189

Table 3-14
Year

Class A Volume (m3)

Low-Level Radioactive Waste by Volume
Class B Volume (m3)

Class C Volume (m3)

Total Volume (m3)

Barnwell
2023
2022
2021
2020
2019
Median

236.9
156.9
397.0
836.1
246.5
246.5

34.1
23.8
21.1
48.4
39.3
34.1

23.5
18.4
10.2
6.8
19.1
18.4

294.5
199.1
428.3
891.4
305.0
305.0

91,823.0
63,994.8
25,185.5
27,805.3
118,516.4
63,994.8

0.0
0.0
0.0
0.0
0.0
0.0

91,823.0
63,994.8
25,185.5
27,805.3
118,516.4
63,994.8

334.7
734.4
512.9
371.2
493.1
493.1

3.8
3.4
6.0
3.6
0.0
3.6

0.0
0.0
0.0
0.0
0.0
0.0

399.0
755.5
566.4
433.0
592.3
566.4

769.7
706.1
624.8
803.1
756.6
756.6

140.3
113.5
123.8
57.9
104.2
113.5

47.5
66.4
47.0
32.7
49.7
47.5

957.4
886.0
795.6
893.7
910.4
893.7

93,164.2
65,592.2
26,720.2
29,815.7
120,012.6
65,592.2

178.2
140.8
150.9
110.0
143.5
143.5

70.9
84.8
57.2
39.5
68.8
68.8

93,473.9
65,835.4
26,975.9
30,023.3
120,324.3
65,835.4

EnergySolutions
2023
2022
2021
2020
2019
Median
Richland
2023
2022
2021
2020
2019
Median

Waste Control Specialists
2023
2022
2021
2020
2019
Median
Annual Total
2023
2022
2021
2020
2019
Median

Note: Original units were cubic feet. Cubic feet were converted to cubic meters by multiplying by 0.0283 m3/ft3.
Source: DOE 2024-TN10120.

3-190

Table 3-15

Activity Class C
(curies)

Total Activity
(curies)

475.31
499.60
743.96
464.81
3,315.23
499.60

12,870.47
29,134.89
46.57
18.28
26,986.16
12,870.47

13,533.24
29,749.07
923.80
643.11
30,553.29
13,533.24

0.00
0.00
0.00
0.00
0.00
0.00

6,339.55
6,969.43
6,368.76
15,608.41
9,553.56
6,969.43

2023
407.34
2022
324.16
2021
265.51
2020
999.90
2019
658.32
Median
407.34
Waste Control Specialists

604.93
724.76
6,321.28
7,861.04
0.00
724.76

0.00
0.00
0.00
0.00
0.00
0.00

1,017.40
1,048.93
6,589.54
9,235.54
669.66
1,048.93

2023
2022
2021
2020
2019
Median

888.36
979.88
806.38
1,156.49
723.33
888.36

3,711.31
4,953.42
7,681.52
3,081.13
4,935.57
4,935.57

147,140.44
110,591.00
98,842.64
19,695.26
88,333.14
98,842.64

151,740.11
116,524.30
107,330.54
23,932.89
93,992.05
107,330.54

7,822.71
8,388.05
7,573.93
17,924.83
11,187.11
8,388.05

4,791.54
6,177.78
14,746.76
11,406.99
8,250.80
8,250.81

160,010.91
139,725.89
98,889.21
19,713.54
115,319.30
115,319.30

172,630.29
154,291.74
121,212.65
49,419.95
134,768.56
134,768.55

Year

Activity Class A
(curies)

Low-Level Radioactive Waste by Activity
Activity Class B
(curies)

Barnwell
2023
2022
2021
2020
2019
Median

187.46
114.58
133.27
160.02
251.90
160.02

EnergySolutions
2023
2022
2021
2020
2019
Median

6,339.55
6,969.43
6,368.76
15,608.41
9,553.56
6,969.43

Richland

Annual Total
2023
2022
2021
2020
2019
Median

Source: DOE 2024-TN10120.

3-191

3.15.1.8.1 Summary of PPE Values for Transport of Radioactive Waste from New Reactors

2
3
4
5
6
7
8
9
10
11
12
13
14
15

In NUREG-0170, Final Environmental Statement on the Transportation of Radioactive Material
by Air and Other Modes (NRC 1977-TN417, NRC 1977-TN6497), the NRC evaluated the
shipment of radioactive material, including shipments of unirradiated fuel, SNF, and radioactive
waste to and from nuclear power plants. The NRC concluded in NUREG-0170 that the average
radiation dose to the population at risk from normal transportation is a small fraction of the limits
recommended for members of the general public from all sources of radiation other than natural
and medical sources and is a small fraction of the natural background dose. In addition, the
NRC determined that the radiological risk from accidents in transportation is small, amounting to
about 0.5 percent of the normal transportation risk on an annual basis. The NRC also
determined in NUREG-0170 that the environmental impacts of normal transportation of
radioactive materials and the risks attendant to accidents involving radioactive material
shipments are sufficiently small to allow continued shipments by all modes. The doses from
radioactive waste accidents were negligible when compared to the doses from accidents
involving spent fuel shipments.

16
17
18
19
20
21
22
23
24

Previous LWR ESP and COL environmental analyses of the nonradiological impacts from
accidents involving the transportation of LLRW (injuries and death from physical collisions
involving truck LLRW shipments) have shown the risks to be low and the environmental impact
finding was SMALL. The results from these environmental analyses are shown in Table 3-16.
There is uncertainty as to the design of new reactors and how that relates to the generation of
LLRW; most designs are expected to generate lower volumes of LLRW than LWRs due to their
having less complex systems, structures, and components. This should result in a much lower
number of annual LLRW shipments but will depend on the capacity of the onsite radiological
waste storage building.

25
26

Based on the above information, Table 3-16 presents the PPE for transport of radioactive waste
from new reactors. This PPE consists of one component:

27
28
29
30

The maximum annual round-trip shipment distance (293,145 km) presented below in
Table 3-16. The annual shipments associated with the round-trip shipment distance have been
normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent
capacity factor and a shipment volume of 2.34 m 3/shipment from WASH-1238.

31
32
33
34

This PPE does not apply to situations where a new reactor applicant proposes shipping the
reactor’s radioactive waste by air, ship, or barge; or where a new reactor applicant proposes
that a radioactive waste transportation package for the new reactor be approved using the
provisions of 10 CFR 71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d) (10 CFR Part 71-TN301).

3-192

Table 3-16

Annual Nonradiological Impacts of Transporting Waste from the Site

Site Name
WASH-1238 (NRC 2006-TN7)
North Anna Power Station Unit 3 ESP (NRC
2006-TN7)
Clinton Exelon ESP (NRC 2006-TN672)
Grand Gulf ESP (NRC 2006-TN674)
Vogtle Units 3 and 4 ESP (NRC 2008-TN673)
Calvert Cliffs COL (NRC 2011-TN1980)
South Texas Units 3 and 4 COL (NRC 2011TN1722)
Virgil C. Summer Units 2 and 3 COL (NRC 2011TN1723)
Levy Units 1 and 2 COL (NRC 2012-TN1976)
Comanche Peak Units 3 and 4 COL (NRC 2011TN6437)
Enrico Fermi Unit 3 COL (NRC 2013-TN6436)
William States Lee Units 1 and 2 COL (NRC
2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL (NRC 2016TN6434)
Bell Bend COL (NRC and USACE 2016-TN6562)
Clinch River ESP (NRC 2019-TN6136)
Maximum Estimate
(a)
(b)

(c)

2
3
4
5
6
7
8
9
10

Annual Total
Round-Trip
Shipment
Distance(a,b) Accidents Injuries per Fatalities
(km)
per Year(b)
Year(b)
per Year(b)
(c)
(c)
(c)
–
–
–
–(c)
–(c)
–(c)
–(c)
–(c)
–(c)
–(c)
33,600
14,400
49,600

–(c)
–(c)
0.0095
0.0067
0.023

–(c)
–(c)
0.0065
0.0033
0.011

–(c)
–(c)
0.00031
0.00021
0.00072

33,600

0.016

0.0078

0.00049

33,600
174,400

0.016
0.077

0.0078
0.040

0.00049
0.0026

182,400
33,600

0.085
0.016

0.042
0.0078

0.0026
0.00049

233,988
36,800

0.17
0.017

0.097
0.0085

0.0060
0.00053

83,200
293,145
293,145

0.076
0.17
0.17

0.0045
0.11
0.11

0.00016
0.0049
0.0060

The total shipment distance is based on the number of annual shipments multiplied by the round-trip shipping
distance. The round-trip distance is used because nonradiological vehicle accident impacts could occur on the
return trip.
In determining the round-trip shipment-km, accidents per year, injuries per year, and fatalities per year, the
number of shipments was calculated assuming the average waste shipment capacity of 2.34 m 3 (82.6 ft3) per
shipment applied in WASH-1238 (AEC 1972-TN22) (108 m3/yr divided by 46 shipments/year yields 2.34 m3 per
shipment). The number of shipments was also normalized to 880 MW(e).
Not analyzed.

3.15.1.9

Transportation of SNF from New Reactors

This section discusses the radiological and nonradiological environmental impacts from the
potential shipments of SNF for normal operating, or incident-free conditions and transportation
accidents. For the previous new reactor EISs, the staff performed an independent analysis of
the environmental impacts of transporting spent fuel from the proposed and alternative sites to a
spent fuel disposal repository. The staff has also performed an independent analysis for the
transportation of SNF to a private ISFSI and two Consolidated Interim Storage Facilities (CISFs)
for SNF and HLW, as published in three EISs (NRC 2001-TN6514, NRC 2021-TN10124, NRC
2022-TN10125).

3-193

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

For the purposes of these new reactor transportation analyses, the NRC staff considered the
proposed Yucca Mountain site in Nevada as a surrogate destination. The NRC has not made a
licensing decision about the DOE application for the proposed geologic repository at Yucca
Mountain. However, the NRC staff considers an estimate of the impacts of the transportation of
spent fuel to a possible repository in Nevada to be a reasonable bounding estimate of the
transportation impacts on a spent fuel interim storage or disposal facility because of the
distances involved and the representativeness of the distribution of members of the public in
urban, suburban, and rural areas (i.e., population distributions) along the shipping routes. In
addition, as noted in Section 3.15.1.3, Additional NRC Information Sources, the new reactor
transportation analyses using truck shipments of 0.5 MTU were normalized with respect to
power level and shipment quantities to allow a comparison to the results presented in Table S-4
of 10 CFR 51.52 (TN250). The results of the new reactor transportation analyses for SNF as
normalized for comparison to Table S-4 are provided in Table 3-17, Table 3-18, and Table 3-19,
for incident-free SNF impacts, radiological accident SNF impacts, and nonradiological accident
SNF impacts, respectively.

16
17
18
19
20
21
22
23
24
25
26
27

For the licensing action of the Private Fuel Storage Facility (PFSF) ISFSI, the staff analyzed the
human health impacts from the transportation of SNF in NUREG-1714, (NRC 2001-TN6514).
Section 5.7, Human Health Impacts of SNF Transportation, discusses the radiological and
nonradiological human health impacts associated with transportation of SNF from nuclear power
plants to the PFSF. For cross-country transportation to the proposed PFSF, only shipments by
rail are analyzed because Private Fuel Storage planned to receive only rail transportation
packages under its NRC license with the potential for short travel distances by heavy-haul
trucks or by barges when necessary. Based on the results of the transportation analysis, the
staff found that annual and cumulative radiological impacts of transporting SNF to the proposed
PFSF would be small. Also, the analytical results for transportation of SNF to and from the
proposed PFSF are consistent with earlier analyses of SNF risks reported in NUREG-0170
(NRC 1977-TN417, NRC 1977-TN6497).

28
29
30
31
32
33
34
35
36
37
38
39
40
41
42

In the CISF EISs, the staff estimated the potential radiological impacts on workers and the
public from the proposed rail transportation of SNF from nuclear power plants and ISFSIs to the
proposed CISF based on prior NRC transportation risk estimates in NUREG-2125, Spent Fuel
Transportation Risk Assessment (NRC 2014-TN3231). In the NUREG-2125 analysis, the staff
performed a transportation risk assessment to calculate worker and public doses and risks from
the transportation of SNF along various representative national routes under incident-free and
accident conditions. In that analysis, the staff calculated occupational doses for groups of
workers, including rail crew, escorts in transit, and railyard workers, as well as crew and escorts
at stops. Because the resulting dose estimates provided in NUREG-2125 were presented for
single shipments and for each kilometer traveled and for each hour of transportation, the staff
scaled the results by these variables (e.g., number of shipments, distance, and time) to
generate estimates that were applicable to the proposed CISF projects. The staff selected a
representative route that was bounding for the proposed shipments of SNF to the proposed
CISF and scaled the calculated doses to match the number of proposed shipments and, as
applicable, the shipment distance and time.

3-194

1
2

Table 3-17

Incident-Free Radiological Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site

Site Name
North Anna Power Station Unit 3
ESP (NRC 2006-TN7)
Clinton Exelon ESP (NRC 2006TN672)
Grand Gulf ESP (NRC 2006TN674)
Vogtle Units 3 and 4 ESP (NRC
2008-TN673)
Calvert Cliffs Unit 3 COL (NRC
2011-TN1980)
South Texas Units 3 and 4 COL
(NRC 2011-TN1722)
Virgil C. Summer Units 2 and 3
COL (NRC 2011-TN1723)
Levy Units 1 and 2 COL (NRC
2012-TN1976)
Comanche Peak Units 3 and 4
COL (NRC 2011-TN6437)
Enrico Fermi Unit 3 COL (NRC
2013-TN6436)
William States Lee Units 1 and 2
COL (NRC 2013-TN6435)
PSEG ESP (NRC 2015-TN6438)
Turkey Point Units 6 and 7 COL
(NRC 2016-TN6434)
Bell Bend COL (NRC and USACE
2016-TN6562)
Clinch River ESP (NRC 2019TN6136)
NUREG-2266 (NRC 2024TN10333)(c)
Maximum Estimate

Annual
Shipments(a)
90

Shipping
Distance
(km)
4,410

Annual
Total OneWay
Shipment
Distance(a)
(km)
396,900

3,076

276,840

6.4

0.41

3,718

334,620

7.8

0.62

4,091

163,640

7.3

0.38

4,568

210,128

9.4

0.53

2,922

175,320

8.0

0.37

4,096

188,416

7.4

0.35

4,520

180,800

8.2

0.42

9.5

2,568

24,396

2.0

0.37

0.11

40.3

3,481

140,284

6.4

0.25

4,041

157,599

7.5

0.37

54.5

4,470

243,615

0.63

4,977

298,620

9.9

0.59

4,090

179,960

4.3

0.35

137

3,689

505,393

2.8

0.97

4,458

347,724

4.4

11.4

0.637

505,393

0.97

Population Impacts (personrem/yr)(b)

Workers
9.2

Public
Onlookers
32

(a) The total shipment distance is based on the number of annual shipments multiplied by the
shipping distance.
(b) Normalized to Reference LWR (880 MW(e) net).
(c) Largest annual impact for an existing LWR from NUREG-2266 Table 3-10 (NRC 2024-TN10333).

3-195

Public
Along
Route
0.82

1
2

Table 3-18

Radiological Accident Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site

Site Name

Annual
Shipments(a)

Annual Total
Population
One-Way
Impacts
Shipping
Shipment
(personDistance
Distance(a)
rem/yr)(b)
(km)
(km)
4,410
396,900
5.00E-04(c)

Burnup
(GWd/MTU)
62 (LWRs)(d)
133 (TRISO)

North Anna Power Station Unit 3
ESP (NRC 2006-TN7)

Clinton Exelon ESP (NRC 2006TN672)

3,076

276,840

2.30E-04(c)

62 (LWRs)(d)
133 (TRISO)

Grand Gulf ESP (NRC 2006TN674)

3,718

334,620

4.10E-04(c)

62 (LWRs)(d)
133 (TRISO)

Vogtle Units 3 and 4 ESP (NRC
2008-TN673)

4,091

163,640

2.20E-05

62 (LWR)(d)

Calvert Cliffs Unit 3 COL (NRC
2011-TN1980)

4,568

210,128

8.40E-05

52 (LWR)

South Texas Units 3 and 4 COL
(NRC 2011-TN1722)

2,922

175,320

1.50E-04

32.3 (LWR)

Virgil C. Summer Units 2 and 3
COL (NRC 2011-TN1723)

4,096

188,416

1.80E-05

50.5 (LWR)

Levy Units 1 and 2 COL (NRC
2012-TN1976)

4,520

180,800

9.20E-05

62 (LWR)(d)

Comanche Peak Units 3 and 4
COL (NRC 2011-TN6437)

9.5

2,568

24,396

5.90E-05

46.2 (LWR)

Enrico Fermi Unit 3 COL (NRC
2013-TN6436)

40.3

3,481

140,284

3.10E-06

46 (LWR)

William States Lee Units 1 and 2
COL (NRC 2013-TN6435)

4,041

157,599

7.10E-05

62 (LWR)

PSEG ESP (NRC 2015-TN6438)

54.5

4,470

243,615

2.00E-04

54.2 (LWR)

Turkey Point Units 6 and 7 COL
(NRC 2016-TN6434)

4,977

298,620

5.20E-05

50.5 (LWR)

Bell Bend COL (NRC and
USACE 2016-TN6562)

4,090

179,960

1.28E-04

52 (LWR)

Clinch River ESP (NRC 2019TN6136)

137

3,689

505,393

7.50E-06

51 (LWR)

NUREG-2266 (NRC 2024TN10333)(e)

4,252

191,340

2.96E-05

80 (LWR)

505,393

5.00E-04

80 (LWRs)(d)
133 (TRISO)

Maximum Estimate
(a)
(b)
(c)
(d)
(e)

The total shipment distance is based on the number of annual shipments multiplied by the shipping distance.
Normalized to Reference LWR (880 MW(e) net).
Maximum population impact if multiple reactor types evaluated.
Peak rod burnup.
Largest annual impact for an existing LWR from NUREG-2266 Table 3-14 (NRC 2024-TN10333).

3-196

1
2

Table 3-19

Nonradiological Accident Impacts for Shipping Spent Nuclear Fuel to the
Yucca Mountain Site

Annual
Site Name
Shipments(a)
North Anna Power Station Unit
90
3 ESP (NRC 2006-TN7)
90
Clinton Exelon ESP (NRC
2006-TN672)
90
Grand Gulf ESP (NRC 2006TN674)
40
Vogtle Units 3 and 4 ESP
(NRC 2008-TN673)
46
Calvert Cliffs Unit 3 COL
(NRC 2011-TN1980)
60
South Texas Units 3 and 4
COL (NRC 2011-TN1722)
46
Virgil C. Summer Units 2 and
3 COL (NRC 2011-TN1723)
40
Levy Units 1 and 2 COL (NRC
2012-TN1976)
9.5
Comanche Peak Units 3 and 4
COL (NRC 2011-TN6437)
40.3
Enrico Fermi Unit 3 COL
(NRC 2013-TN6436)
39
William States Lee Units 1 and
2 COL (NRC 2013-TN6435)
54.5
PSEG ESP (NRC 2015TN6438)
60
Turkey Point Units 6 and 7
COL (NRC 2016-TN6434)
44
Bell Bend COL (NRC and
USACE 2016-TN6562)
137
Clinch River ESP (NRC 2019TN6136)
NUREG-2266 (NRC 202478
TN10333)(c)
Maximum Estimate

Annual Total
Round-Trip
Shipment
Injuries Fatalities
Shipping
Distance
Accidents per
per
Distance
(km)(a)
per Year(b) Year(b)
Year(b)
(km)
4,410
793,800
-(c)
-(c)
-(c)
3,076

553,680

-(c)

3,718

669,240

-(c)

4,091

327,280

0.081

0.067

0.0036

4,568

420,256

0.16

0.099

0.0076

2,922

350,640

0.20

0.13

0.0062

4,096

376,832

0.11

0.071

0.0056

4,520

361,600

0.15

0.087

0.0062

2,568

48,792

0.011

0.062

0.0042

3,481

280,569

0.15

0.068

0.0046

4,041

315,198

0.11

0.072

0.0056

4,470

487,230

0.28

0.13

0.0080

4,977

597,240

0.15

0.098

0.0068

4,090

359,920

0.33

0.019

0.00067

3,689

1,010,786

0.32

0.21

0.016

4,252

331,656

0.211

0.093

0.0077

1,010,786

0.33

0.21

0.016

(a) The total shipment distance is based on the number of annual shipments multiplied by the roundtrip shipping distance. The round-trip distance is used because nonradiological vehicle accident
impacts could occur on the return trip.
(b) Normalized to Reference LWR (880 MW(e) net).
(c) Not analyzed.
(d) Largest annual impact for an existing LWR from NUREG-2266 Table 3-16 (NRC 2024-TN10333).

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3.15.1.9.1 Differences between Truck and Rail Transportation Modes

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4
5
6
7
8
9

Several differences between the truck and rail transportation modes should be considered when
selecting the transportation mode for assessing the impacts of transporting new reactor SNF.
First, there is a significant difference in the MTU load that can be carried by each. Truck
shipments are likely not to contain more than approximately 2 MTU (e.g., 4 PWR SNF
assemblies) where 0.5 MTU has been applied in previous staff analyses for a comparison to
Table S-4. Rail transportation packages could contain upwards of approximately 18.5 MTU
(e.g., 37 PWR SNF assemblies) (NRC 2020-TN6683, NRC 2018-TN6685). Thus, for a set MTU
quantity of new reactor SNF, fewer numbers of shipments are necessary for the rail mode.

10
11
12
13
14
15
16
17

The rail mode would likely involve less radiation exposure to members of the public because
people traveling on roads would be next to truck shipments and there is generally a buffer zone
on each side of the rail right-of-way going through residential neighborhoods. There are also
access limitations for the shipment of SNF by rail. It is not certain that all new reactor sites
would have rail access. Thus, some portion of the transportation route may have to be
performed using heavy-haul trucks for rail shipments. Such heavy-haul truck shipments are
expected to be heavily monitored and controlled resulting in low to negligible impacts on
members of the public.

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19
20
21
22
23
24
25

Therefore, it is expected that truck shipments would have larger incident-free impacts than rail
shipments due to the larger number of shipments (e.g., as much as 37 times—0.5 MTU versus
18.5 MTU) and due to the greater potential for radiation exposure to members of the public. In
addition, 49 CFR 397.101 (49 CFR Part 397-TN6621) requires that placarded radioactive
material shipments made by truck are operated on routes that minimize radiological risks.
Similarly, 49 CFR 172.820 requires that rail routes for highway-route–controlled quantities of
radioactive material consider factors that would also serve to minimize radiological risks (see
49 CFR Part 172-TN6616, Appendix D).

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27
28

When considering impacts from transportation accidents, both rail and truck packages have a
very low probability of a radioactive release. As stated in the summary for Chapter 3, Cask
Response to Impact Accidents, of NUREG-2125 (NRC 2014-TN3231):

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32
33
34
35
36
37
38
39
40

Detailed FE [finite element] analyses performed for two spent fuel transportation
rail casks indicate that casks are very robust structures capable of withstanding
almost all impact accidents without release of radioactive material. In fact,
when spent fuel is transported within an inner welded canister or in a truck
cask, no impacts result in release. Even the rail cask without an inner welded
canister can withstand impacts much more severe than the regulatory
impact without releasing any material.
And with respect to truck packages:
Assessment of previous analyses performed for spent fuel truck transportation
casks, including impacts onto flat rigid targets, into cylindrical rigid targets, by
locomotives, and by falling bridge structures, indicate that truck casks will not
release their contents in any impact accidents.

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3
4

Chapter 5, Transportation Accidents, of NUREG-2125 (NRC 2014-TN3231) concluded the
overall collective dose risks are very small to negligible for the two types of extra-regulatory
accidents (accidents involving a release of radioactive material and loss-of-lead-shielding
accidents).

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6
7
8
9

For transportation accidents involving severe fires, NUREG/CR-7209 (Fort et al. 2017-TN6692)
evaluated four severe roadway and railway fires for their potential impact on spent fuel
transportation packages. The analyses found that NRC regulations and packaging standards
provide a high degree of protection of public health and safety against releases of radioactive
material in real-world transportation accidents involving fires.

3.15.1.9.2 Summary of PPE Values for Transport of Irradiated New Reactor Fuel

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12

Based on the above information, Table 3-17 and Table 3-19 present the PPE for transport of
irradiated new reactor fuel. This PPE consists of two components:

13
14
15
16

The maximum annual one-way shipment distance (505,393 km) presented below in Table 3-17.
The annual shipments associated with the one-way shipment distance have been normalized to
a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a
shipment capacity of 0.5 MTU/shipment from WASH-1238.

17
18
19
20

The maximum annual round-trip shipment distance (1,010,786 km) presented below in
Table 3-19. The annual shipments associated with the round-trip shipment distance have been
normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent
capacity factor and a shipment capacity of 0.5 MTU/shipment from WASH-1238.

21
22

Based on the radiological accident impacts presented below in Table 3-18, an additional
component is established for the PPE:

23
24

• A maximum peak rod burnup of 80 GWd/MTU for UO2 fuel and peak pellet burnup of
133 GWd/MTU for TRISO fuel.

25
26
27
28
29
30
31

This PPE does not apply to situations where a new reactor applicant proposes shipping the
irradiated fuel by air, ship, or barge; or where a new reactor applicant proposes that an
irradiated fuel transportation package for the new reactor be approved using the provisions of
10 CFR 71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d) (10 CFR Part 71-TN301), such as might
be applied for when shipping an entire irradiated reactor core. In addition, the irradiated new
reactor fuel must be shipped in a transportation package that meets all of the applicable NRC
regulations.

3.15.2 Transportation Impacts

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34
35

The NRC staff identified the following three environmental issues associated with the
radiological and nonradiological environmental impacts from incident-free transportation and
transportation accident conditions:

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39
40

• shipment of unirradiated fuel to the new reactor site,
• shipment of LLRW and mixed waste to offsite disposal facilities, and
• shipment of SNF to an interim storage facility or a permanent geologic repository.
This assessment will draw upon previous analyses for their assumptions, shipment parameters,
and routing information and provide a basis that a new reactor applicant could apply for

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bounding the potential environmental impacts for their non-LWR fuel and waste, given there is a
certain amount of uncertainty in transport packaging and processing.

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6
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8
9
10
11
12

A couple of notable conditions in this analysis can be accepted without specific new reactor
design information. First, it is likely that new reactor developers will use HALEU fuel with
resulting longer refueling cycling times than the 2-year refueling frequencies of LWRs that were
assessed in the new reactor EISs. Thus, the number of shipments of fresh fuel to the new
reactor site and the potential number of SNF shipments from the site could be significantly less
than previously assessed for new reactor LWRs. The previous analyses, whether they used
existing certified transport packages or not, were based on a specific quantity of nuclear fuel in
each shipment. For example, WASH-1238 (AEC 1972-TN22) assumed a 0.5 MTU per SNF
truck shipment. Thus, this is another shipment parameter that could be applied as a bounding
value for new reactor fuel shipments.

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14
15
16
17
18
19
20

Second, there are a number of unknowns or questions related to several aspects of non-LWR
fuel shipments. Prior transportation risk assessments were reviewed for their applicability to
support resolution of new reactor fuel transportation issues. In addition, PNNL has prepared a
report for the NRC regarding transportation analysis for non-LWR reactor designs (Maheras
2020-TN6509). While Section 6.2 in NRC RG 4.2 (NRC 2024-TN7081) provides detailed
guidance for how to estimate transportation-related impacts for LWRs, the PNNL report
provides additional guidance for estimating transportation-related impacts for non-LWRs in the
following areas:

• applicability of NRC and DOT regulations to the shipment of non-LWR fuel and waste;

22
23

• absence of certified packages for shipping the unirradiated fuel, spent fuel, and radioactive
waste associated with non-LWRs;

24
25

• external dose rates associated with the shipment of non-LWR unirradiated fuel, spent fuel,
and radioactive waste;

• transportation routing for non-LWR shipments;

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28

• chemical and physical forms associated with the non-LWR unirradiated fuel, spent fuel, and
radioactive waste;

29
30

• number of shipments associated with unirradiated fuel, spent fuel, and radioactive waste
shipments;

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32

• radionuclide inventory per shipment for non-LWR unirradiated fuel, spent fuel, and
radioactive waste;

33
34

• conditional probabilities and release fractions associated with transportation accidents
involving non-LWR fuel and waste shipments; and

• comparison of transportation risk assessment results to various criteria.

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37
38

In addition to the PNNL report (Maheras 2020-TN6509), other transportation analysis
documents are discussed for their usefulness to support the environmental conclusions in
Section 3.15.1.

3.15.2.1

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41

The staff’s evaluation of the transport of unirradiated new reactor fuel focused on incident-free
radiological impacts and the nonradiological impacts of transportation accidents. This is a

Transportation of Unirradiated New Reactor Fuel

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3
4
5
6
7
8
9

Category 1 issue. If the values and assumptions of the PPE that the transport of unirradiated
new reactor fuel will fit within the bounds outlined in Table 3-11 and Table 3-12 in
Section 3.15.1.7.1 are met, the impacts can be generically determined to be SMALL and the
maximum transportation estimates are as listed in Table 3-11 and Table 3-12. The staff relied
on the following PPE values and assumptions to reach this conclusion:
• The maximum annual one-way shipment distance (59,160 km) presented in Table 3-11. The
annual shipments associated with the one-way shipment distance have been normalized to
a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor
from WASH-1238 (AEC 1972-TN22).

10
11
12
13

• The maximum annual round-trip shipment distance (118,320 km) presented in Table 3-12.
The annual shipments associated with the round-trip shipment distance have been
normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent
capacity factor from WASH-1238.

14
15
16
17
18
19
20
21
22
23
24

This requires that the unirradiated new reactor fuel shipments be normalized to a net electrical
output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor from WASH-1238.
The PPE applies to situations where the enrichment of the unirradiated new reactor fuel is
20 percent or less, based on the unlimited A 2 value in Table A-1 in 10 CFR Part 71 (TN301) for
unirradiated uranium enriched to 20 percent or less. In addition, the PPE does not apply to
situations in which a new reactor applicant proposes shipping the unirradiated fuel by air, ship,
or barge; or in which a new reactor applicant proposes that an unirradiated fuel transportation
package for the new reactor be approved using the provisions of 10 CFR 71.12, 10 CFR
71.41(c), or 10 CFR 71.41(d) (10 CFR Part 71-TN301). If these assumptions are not met, a
project-specific transportation impact analysis must be performed as part of the new reactor
application.

25
26
27
28
29

Some new reactor designs are anticipated to ship a fully loaded but unirradiated reactor core
from a manufacturing facility to an appropriately licensed reactor site. In the case of shipping a
new reactor core and its unirradiated contents or any other new reactor unirradiated fuel, in
which any of the above conditions are not met, then a project-specific transportation impact
analysis must be performed as part of the new reactor application.

3.15.2.2

31
32
33
34
35
36

The staff’s evaluation of the transport of radioactive waste from new reactors focused on the
nonradiological impacts of transportation accidents. This is a Category 1 issue. If the values and
assumptions of the PPE that the transport of radioactive waste from a new reactor will fit within
the bounds outlined in Table 3-16 in Section 3.15.1.8.1 are met, the impacts can be generically
determined to be SMALL and the maximum transportation estimates are as listed in Table 3-16.
The staff relied on the following PPE value and assumptions to reach this conclusion:

37
38
39
40

The maximum annual round-trip shipment distance (293,145 km) presented in Table 3-16. The
annual shipments associated with the round-trip shipment distance have been normalized to a
net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a
shipment volume of 2.34 m 3/shipment from WASH-1238 (AEC 1972-TN22).

41
42
43
44

This requires that the radioactive waste shipments from new reactors be normalized to a net
electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a
shipment volume of 2.34 m 3/shipment from WASH-1238 (AEC 1972-TN22). In addition, the PPE
does not apply to situations in which a new reactor applicant proposes shipping the radioactive

Transportation of Radioactive Waste from New Reactors

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3
4
5

waste by air, ship, or barge; or in which a new reactor applicant proposes that a radioactive
waste transportation package for the new reactor be approved using the provisions of 10 CFR
71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d) (10 CFR Part 71-TN301). If these assumptions are
not met, a project-specific transportation impact analysis must be performed as part of the new
reactor application.

3.15.2.3

7
8
9
10
11
12
13

Transportation of Irradiated Fuel from New Reactors

The staff’s evaluation of the transport of irradiated fuel from new reactors focused on incidentfree radiological impacts and the radiological and nonradiological impacts of transportation
accidents. This is a Category 1 issue. If the values and assumptions of the PPE that the
transport of irradiated new reactor fuel will fit within the bounds outlined in Table 3-17 and
Table 3-19 are met, the impacts can be generically determined to be SMALL and the maximum
transportation estimates are as listed in Table 3-17, Table 3-18, and Table 3-19. The staff relied
on the following PPE values and assumptions to reach this conclusion:

14
15
16
17

18
19
20
21

• The maximum annual round-trip shipment distance (1,010,786 km) presented in Table 3-19.
The annual shipments associated with the round-trip shipment distance have been
normalized to a net electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent
capacity factor and a shipment capacity of 0.5 MTU/shipment from WASH-1238.

22
23

• A maximum assembly averaged burnup of 80 GWd/MTU for UO2 fuel and peak pellet
burnup of 133 GWd/MTU for TRISO fuel (see Table 3-18).

24
25
26
27
28
29
30
31
32
33

This requires that the irradiated fuel shipments from new reactors be normalized to a net
electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a
shipment capacity of 0.5 MTU/shipment from WASH-1238. The PPE also does not apply to
situations in which a new reactor applicant proposes shipping the irradiated fuel by air, ship, or
barge; or in which a new reactor applicant proposes that an irradiated fuel transportation
package for the new reactor be approved using the provisions of 10 CFR 71.12, 10 CFR
71.41(c), or 10 CFR 71.41(d) (10 CFR Part 71-TN301). In addition, the irradiated new reactor
fuel must be shipped in a transportation package that meets all of the applicable NRC
regulations. If these assumptions are not met, a project-specific transportation impact analysis
must be performed as part of the new reactor application.

34
35
36
37
38

It is recommended that the transportation analysis be performed in manner to the practicable
extent possible to apply impact results from previous NRC or DOE analysis. The basis for
applying these prior results must be justified to show that the new reactor SNF characteristics fit
within the parameters and assumptions applied in the prior transportation analysis, such as was
done for the two CISF EIS transportation analyses (NRC 2021-TN10124, NRC 2022-TN10125).

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3.16 Decommissioning

3.16.1 Baseline Conditions and PPE/SPE Values and Assumptions

3
4
5
6
7
8
9
10

At the end of the operating life of a power reactor, NRC regulations require that the nuclear
facility undergo decommissioning. The NRC defines decommissioning as the safe removal of a
facility from service and the reduction of residual radioactivity to a level that permits termination
of the NRC license. The regulations governing decommissioning of power reactors are found in
10 CFR 50.75 (TN249), 10 CFR 50.82 (TN249), and 10 CFR 52.110 (TN251). The radiological
criteria for termination of the NRC license are in 10 CFR Part 20 (TN283), Subpart E. The
requirements for the minimization of contamination and generation of radioactive waste for
facility design and procedures for operation are addressed in 10 CFR 20.1406 (TN283).

11
12
13
14
15
16
17
18
19

If a new reactor applicant submits an application for an operating license or a COL, or applies
for a license to construct a new nuclear power plant, there is a requirement in 10 CFR 50.33
(TN249) to provide a report (discussed in 10 CFR 50.75 (TN249), and 10 CFR 52.77 refers
back to 10 CFR 50.33) that contains a certification indicating how reasonable assurance will be
provided that funds will be available to complete decommissioning of the facility. In addition, the
regulations for termination of the license in 10 CFR 50.82(a)(4)(i) (TN249) and 10 CFR
52.110(d)(1) (TN251) require the licensee to submit a post-shutdown decommissioning activity
report (PSDAR) to the NRC and a copy to the affected State(s) either before or not later than
2 years after permanent cessation of operations.

20
21
22
23
24
25
26
27

The PSDAR must include a description of the licensee’s planned decommissioning activities, a
schedule for the accomplishment of significant milestones, and an estimate of all expected costs
for radiological decommissioning (this does not include site restoration). The PSDAR is
sometimes referred to as the licensee’s decommissioning plan that provides the
decommissioning strategy for the reactor. The PSDAR must contain, among other things, a
discussion that provides the reasons for concluding that the environmental impacts associated
with project-specific decommissioning activities will be bounded by appropriate previously
issued EISs.

28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43

The PSDAR should also document the results of the licensee’s evaluation of the environmental
impacts associated with project-specific decommissioning activities. The evaluation should
include a comparison of the project-specific environmental impacts of the proposed
decommissioning to the impacts identified in previously issued environmental statements, that
is, NUREG-0586, Supplement 1, Generic Environmental Impact Statement on
Decommissioning of Nuclear Facilities Regarding the Decommissioning of Nuclear Power
Reactors (the Decommissioning GEIS) (NRC 2002-TN665), NUREG-1496, Volume 1, Generic
Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License
Termination of NRC-Licensed Nuclear Facilities (NRC 1997-TN5455), and any previous
project-specific environmental NEPA licensing documents. The NRC will determine whether the
licensee’s PSDAR contains the information required by the regulation. Although the NRC’s
approval of the PSDAR is not required, if the NRC determines that the information provided by
the licensee in the PSDAR does not comply with the regulatory requirements, it will inform the
licensee in writing of the additional information required by the regulations and request a
response. The licensee is required to provide updates to the NRC for review if there are any
significant changes to the PSDAR.

44
45

The licensee is required to submit a License Termination Plan application with its final status
survey strategy to the NRC at least 2 years before they intend to terminate the license. Before

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the completion of decommissioning, the licensee conducts a final status survey to demonstrate
compliance with criteria established in the License Termination Plan; the License Termination
Plan is sometimes referred to in layman’s terms as the approved decommissioning plan for
power reactors. The NRC may verify the survey by one or more of the following: a quality
assurance/quality control review, side-by-side or split sampling of a radiological survey of
selected areas, and independent confirmatory surveys. When the NRC confirms that the criteria
in the License Termination Plan and all other NRC regulatory requirements have been met, the
NRC either terminates or amends the license, depending on the licensee’s decision to use the
licensed area.

10
11
12
13

The Decommissioning GEIS (NRC 2002-TN665) determined the environmental impacts would
be SMALL for the following resource areas, would be limited to operational areas, would not be
detectable or destabilizing and are expected to have a negligible effect on the impacts of
terminating operations and decommissioning:

• Onsite Land Use

• Water Use

• Water Quality

• Air Quality

• Aquatic Ecology within the operational area

• Terrestrial Ecology within the operational area

• Radiological

• Radiological Accidents (non-spent-fuel-related)

• Occupational Issues

• Socioeconomic

24
25

• Onsite Cultural and Historic Resources for plants where the disturbance of lands beyond the
operational areas is not anticipated

• Aesthetics

• Noise

• Transportation

• Irretrievable Resource

30
31
32
33
34

Environmental justice and threatened and endangered species are site-specific issues in the
Decommissioning GEIS where a generic environmental impact determination could not be
reached. In addition, four other issues also do not have generic environmental impact
determinations in the Decommissioning GEIS, including offsite land use and aquatic ecology,
terrestrial ecology, and historic and cultural resource activities beyond the operational area.

35
36

The following two environmental issues were not identified in the Decommissioning GEIS and
are assessed in the next section:

• Nonradiological waste

• Greenhouse gases

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3.16.2 Decommissioning Impacts

2
3
4
5
6

This section addresses the potential environmental impacts of the decommissioning of the new
reactor facility and the management of SNF that may remain at the site until it is removed and
the license is terminated. The continued storage of spent fuel during the period of time past
permanent cessation of reactor operations is discussed in Section 3.14.2.6, Storage and
Disposal of Radiological Wastes.

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24

The NRC staff evaluated the environmental impacts during the decommissioning of nuclear
power reactors as residual radioactivity at the site is reduced to levels that allow for termination
of the NRC license. This evaluation was documented in the Decommissioning GEIS
(NUREG-0586, Supplement 1; NRC 2002-TN665). NUREG-0586, Supplement 1, is
incorporated here by reference. The License Renewal GEIS (NUREG-1437 Revision 1,
Section 4.12.2 [NRC 2024-TN10161]) references the Decommissioning GEIS and describes the
impacts associated with decommissioning existing LWRs (a nuclear facility with a large
footprint). This section describes and discusses the environmental consequences of terminating
nuclear power plant operations and decommissioning, but the only impacts attributable to the
proposed action (license renewal) are the effects of an additional 20 years of operations on the
impacts of decommissioning. The majority of the impacts associated with plant operations would
cease with reactor shutdown; however, some impacts would remain unchanged, while others
would continue at reduced or altered levels. Some new impacts might also result directly from
terminating nuclear power plant operations. Section 4.12.2.1, Termination of Operations and
Decommissioning of Existing Nuclear Power Plants, of the License Renewal GEIS discusses
the various impacts by resource area; some could be quantified as having small impacts, such
as radiological impacts, while others could have higher impacts, such as socioeconomics (NRC
2024-TN10161). The License Renewal GEIS concluded the following:

25
26
27
28

The effects of license renewal on impacts of terminating nuclear power plant
operations and decommissioning are considered a single environmental issue.
Because the impacts are expected to be SMALL at all plants and for all
environmental resources, it is considered a Category 1 issue.

29
30

The License Renewal GEIS discussion above informs the impacts expected for
decommissioning a new reactor and are incorporated here by reference.

31
32
33
34
35
36
37

At the initial licensing stage, new reactor applicants are not required to submit information
regarding the specific method chosen for decommissioning or the schedule, but financial
planning is required per 10 CFR 50.75 “Reporting and recordkeeping for decommissioning
planning” and 10 CFR 50.82(a)(8) “Termination of license” (10 CFR Part 50-TN249). However,
a new reactor applicant should provide a discussion in the application’s ER that demonstrates
whether the environmental impacts of decommissioning discussed in NUREG-0586,
Supplement 1 (NRC 2002-TN665) would bound those for the new reactor design.

38
39
40
41
42
43
44
45

The NRC staff’s evaluation of the environmental impacts of decommissioning presented in
NUREG-0586, Supplement 1, considered environmental issues for LWRs and three
permanently shutdown facilities that included a fast breeder reactor and two high-temperature
gas-cooled reactors (NRC 2002-TN665). The Decommissioning GEIS identified whether the
environmental issues were considered generic to all decommissioning sites or project-specific. If
the issue was considered generic, then it was assigned a significance level of either SMALL,
MODERATE or LARGE. For the environmental issues assessed in the Decommissioning GEIS,
most impacts were considered generic and SMALL for all plants, regardless of the activities and

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identified variables. This is because the impacts would be limited to operational areas, would
not be detectable or destabilizing, and are expected to have a negligible effect on the impacts of
terminating operations and decommissioning. The two issues that were determined to require a
project-specific review were EJ and threatened and endangered species. Four issues in the
Decommissioning GEIS were considered to be conditionally project-specific:

• land use involving offsite areas to support decommissioning activities,

• aquatic ecology for activities beyond the licensed operational area,

• terrestrial ecology for activities beyond the licensed operational area, and

9
10
11

• historic and cultural resources (archaeological, architectural, structural, historic) for activities
within and beyond the licensed operational area with no current (i.e., at the time of
decommissioning) evaluation of resources for NRHP eligibility.33

12
13

Table 3-20 provides a summary of the impacts and findings for each of the Decommissioning
GEIS’s evaluated environmental issues.

14
15

Table 3-20

Summary of the Environmental Impacts from Decommissioning Nuclear
Power Facilities (NRC 2002-TN665)

Environmental Issue
Onsite Land Use
• Onsite land use
activities
• Offsite land use
activities

NUREG-0586
S1 Section
No.
4.3.1

Generic

NUREG-0586
S1 Finding

Yes

SMALL

Site-specific

SMALL

Water Use

4.3.2

Yes

Water Quality
• Surface Water
• Groundwater

4.3.3

Yes

Air Quality

4.3.4

SMALL
SMALL

Yes

SMALL

Summary of NUREG-0586 S1
Decommissioning utilizes areas
used during construction.
Decommissioning activities that
affect offsite land use are not
expected unless major upgrades
to transportation links are
required.
Significantly smaller than water
use during operation.
Application of common BMP's;
NPDES permits regulate
intentional releases of
hazardous materials;
considerable attention is placed
on minimizing spills
Activities extend over years and
BMPs can be used to minimize
fugitive dust

In some cases, the nuclear power plant itself may be considered a historic property for its unique
design or contribution to a significant historic or engineering achievement. Ultimately, historic and cultural
resources at each site can be quite different and must be assessed at a plant-specific level and in
consultation with SHPOs, Tribal representatives, and other interested parties.

3-206

Table 3-20

Summary of the Environmental Impacts from Decommissioning Nuclear
Power Facilities (NRC 2002-TN665) (Continued)

Environmental Issue

NUREG-0586 S1
Section No.

Aquatic Ecology
• Activities within the
operational area
• Activities beyond the
operational area

4.3.5

Terrestrial Ecology
• Activities within the
operational area
Activities beyond the
operational area

4.3.6

Threatened and
Endangered Species

4.3.7

Radiological
• Occupational dose
Dose to the public

4.3.8

Generic

NUREG-0586
S1 Finding

Yes

SMALL

Site-specific

Yes

SMALL

Site-specific

Yes
Yes

SMALL
SMALL

3-207

Summary of
NUREG-0586 S1
If decommissioning
does not include
removal of
shoreline or inwater structures,
very little aquatic
habitat is expected
to be disturbed
during
decommissioning.
When there is a
decommissioning
activity outside the
operational area,
the significance of
the potential
impacts is more
difficult to define
and will depend on
site-specific
considerations.
There is a relatively
distinct/small
operational area
where most or all
site activities occur.
Some sites will
require the
reconstruction or
installation of new
transportation links,
such as railroad
spurs, road
upgrades, or barge
slips.
The likelihood of
impacts to
threatened and
endangered
species is related to
their presence or
absence
Radiological
impacts of
decommissioning,
including demolition
debris that is
LLRW, will remain
within regulatory

Table 3-20

Summary of the Environmental Impacts from Decommissioning Nuclear
Power Facilities (NRC 2002-TN665) (Continued)
NUREG-0586 S1
Section No.

Generic

NUREG-0586
S1 Finding

Radiological Accidents

4.3.9

Yes

SMALL

Occupational Issues

4.3.10

Yes

SMALL

Cost

4.3.11

N/A

Socioeconomic

4.3.12

Yes

SMALL

Environmental Justice

4.3.13

Site-specific

Cultural and Historic
Resources
• Activities within the
operational area

4.3.14
Yes

SMALL

Site-specific

Environmental Issue

3-208

Summary of
NUREG-0586 S1
limits for both
occupational
exposures and to
members of the
public.
Emergency plans
and procedures will
remain in place to
protect health and
safety while the
possibility of
significant spent
fuel pool accidents
exists.
Strict adherence to
NRC, Occupational
Safety and Health
Administration, and
State safety
standards,
practices, and
procedures during
decommissioning.
Evaluation of
decommissioning
cost is not a NEPA
requirement.
Impacts of plant
closure are those
that are observed
by the community,
rather than the
impacts from
decommissioning
activities because
they occur at about
the same time
Needs to be made
on a site-by-site
basis because their
presence and
socioeconomic
circumstances will
be site-specific.
The amount of land
required to support
the
decommissioning
process is relatively

Table 3-20

Summary of the Environmental Impacts from Decommissioning Nuclear
Power Facilities (NRC 2002-TN665) (Continued)
NUREG-0586 S1
Section No.

Generic

NUREG-0586
S1 Finding

Aesthetics

4.3.15

Yes

SMALL

Noise

4.3.16

Yes

SMALL

Transportation

4.3.17

Yes

SMALL

Irretrievable Resource

4.3.18

Yes

SMALL

Environmental Issue
Activities beyond the
operational area

3-209

Summary of
NUREG-0586 S1
small and is a small
portion of the
overall plant site.
Some sites will
require the
reconstruction or
installation of new
transportation links,
such as railroad
spurs, road
upgrades, or barge
slips
BMPs to control
many of the
potentially adverse
impacts of
decommissioning
activities on
aesthetics (e.g.,
dust and noise)
The sources of
noise would be
sufficiently distant
from critical
receptors outside
the plant
boundaries that the
noise would be
attenuated to
nearly. ambient
levels and would be
scarcely noticeable.
Licensees are
expected to comply
with all applicable
regulations when
shipping radioactive
waste from
decommissioning.
If the license is
terminated for
unrestricted use,
then the land will be
available for other
uses and other
irretrievable
resources are
minor.

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22

The NRC staff believes the above impacts, as discussed in Decommissioning GEIS (NRC 2002TN665), are bounding for large LWRs deployed after 2002. The expected methods and
processes for decommissioning new reactors are expected to be similar to existing
decommissioning methods and processes for large LWRs. Regulations specified in §
50.82(a)(4)(i) and § 52.110(d)(1) require that PSDARs provide the reasons for concluding that
appropriate previously issued EISs will bound the environmental impacts from site-specific
decommissioning activities. After the PSDAR is submitted, the licensee must remain in
compliance with § 50.82(a)(6)(ii) or § 52.110(f)(2), as applicable. The staff assumes the
decommissioning of new reactors would likely have no greater impacts than large LWR
decommissioning impacts given that the two project-specific and four conditionally
project-specific issues would be evaluated and addressed at the time of either early
decommissioning (submittal and review of the PSDAR for acceptability) or later (during License
Termination Plan NEPA review). In addition, 10 CFR 50.82 (TN249) or 10 CFR 52.110 (TN251),
as applicable, provide that a licensee shall not perform any decommissioning activities that
result in significant environmental impacts not bounded by previously issued environmental
review documents, such as the Decommissioning GEIS. Licensees that are considering
decommissioning activities that could result in significant environmental impacts and would
otherwise be prohibited by § 50.82(a)(6)(ii) or § 52.110(f)(2), to modify the decommissioning
activity so that the impacts would be bounded, decide not to perform the proposed activity, or
seek NRC approval of a license amendment or exemption request. If the licensee decides to
pursue a license amendment or exemption, its request will trigger an NRC review of the sitespecific environmental impacts of the decommissioning activity under NEPA.

23
24

As discussed in Section 3.16.1, the following two environmental issues were not identified in the
Decommissioning GEIS.

25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43

Regarding nonradiological waste, waste minimization and pollution prevention are important
elements of operations at all nuclear power plants (NRC 2024-TN10161. Nonradiological waste
can include hazardous waste and nonhazardous waste (see Section 3.10.2 for details on
nonradiological waste information). Licensees are required to consider pollution prevention
measures as dictated by the Pollution Prevention Act (Public Law 101 5084; TN6607) and the
Resource Conservation and Recovery Act of 1976, as amended (Public Law 94 580; TN1281).
In addition, licensees have waste minimization programs in place that are aimed at minimizing
the quantities of waste sent offsite for treatment or disposal. Waste minimization techniques
employed by the licensees may include (1) source reduction, which includes (a) changes in
input materials (e.g., using materials that are not hazardous or are less hazardous), (b) changes
in technology, and (c) changes in operating practices and (2) recycling of materials either onsite
or offsite. The establishment of a waste minimization program is also a requirement for
managing hazardous wastes under RCRA. Nonradiological waste will need to be handled in
accordance with applicable Federal and State regulations. It is assumed that licensees would
continue to adhere to all applicable State and Federal laws and pollution prevention plans as
well as applying waste minimization techniques. The staff concludes that, as long as the PPE
assumptions associated with decommissioning and waste management (Section 3.10 of this
NR GEIS) are met, the nonradiological waste impacts from decommissioning a new reactor can
also be generically determined to be SMALL.

44
45
46
47
48

The Decommissioning GEIS (NRC 2002-TN665) does not specifically address the GHG
footprint of decommissioning activities. However, it does list the decommissioning activities and
states that the decommissioning workforce would be expected to be smaller than the
operational workforce, and that the decontamination and demolition activities could take up to
10 years to complete. Finally, it discusses SAFSTOR (also called the SAFSTOR

3-210

1
2
3
4
5
6
7
8
9
10
11

decommissioning option), in which decontamination and dismantlement are delayed for a
number of years (within a cumulative time period of a 50-year time frame (6–10 years is
equivalent to 50 years for SAFSTOR). Equipment and vehicles used during decommissioning
and SAFSTOR activities would emit GHGs, principally CO 2. Combining the PPE values for
GHG emissions for these stages listed in Table 3-1 in Section 3.3.1, 74,000 MT CO2(e) would
be emitted during a 10-year decommissioning period and 40-year SAFSTOR period of two
1,000 MW reactors, or less than 1,500 MT CO2(e)/yr on average. For comparison, in 2022,
total gross annual U.S. GHG emissions were 6,343.2 MMT of CO2(e), of which
5,199.8 MMT CO2(e) were from the energy sector (EPA 2024-TN10121). Estimated annual
GHGs emissions from equipment used during decommissioning are about 0.00003 percent
of the 2019 GHG emissions from the U.S. energy sector.

12
13
14
15
16
17

As noted in Section 3.3.2.2.20, the staff has determined that the contribution of plant life-cycle
GHG emissions to national emissions is a Category 1 issue. The staff concludes that, as long as
the PPE assumptions associated with GHG emissions are met, the GHG impacts from
decommissioning a new reactor can also be generically determined to be SMALL. The generic
analysis for GHG emissions for decommissioning can be relied on without applying any
mitigation measures.

18
19
20
21
22
23
24
25
26
27

Assuming that the decommissioning of a new reactor is similar to current decommissioning
practices, the impacts from decommissioning should be within the bounds described in the
Decommissioning GEIS (NRC 2002-TN665). Based on the above information, the
Decommissioning GEIS can be relied upon for new reactor decommissioning generic or
Category 1 issues with SMALL impacts as presented in Table 3-20. Six site specific or
conditionally project-specific issues along with climate change and cumulative impacts are
Category 2 and their impacts remain undetermined (see Table 3-20 for the environmental
issues marked as Category 2 environmental issues). The Category 2 issues will need to be
addressed within the site-specific environmental review for each application utilizing this
NR GEIS.

3-211

SUMMARY OF FINDINGS

2
3
4
5
6
7
8
9
10

Table 4-1 summarizes the findings of this GEIS, for which 121 environmental issues were
analyzed. The table identifies issues as Category 1, Category 2, or N/A. A Category 1
designation means that the NRC has determined that a generic analysis of environmental
impacts is possible, provided that relevant values and assumptions in the PPE and SPE are
met. Issues for which the impacts are beneficial are also designated as Category 1. A
Category 2 designation means that NRC has determined that a meaningful generic analysis of
environmental impacts is not possible without consideration of project-specific information. The
two N/A issues relate to exposure to EMFs and do not have a national scientific agreement
regarding adverse health effects (i.e., Uncertain impacts).

11
12
13
14
15
16
17
18
19
20
21

For Category 1 issues involving adverse impacts, the NRC staff will evaluate the applicant’s ER
as part of the staff’s determination of whether the proposed reactor project meets the PPE and
SPE for the issue. In its project-specific SEIS, the NRC will set forth its analysis and
determination about whether the project meets the PPE and SPE for the issue and will identify
whether the NRC staff considered any additional information not provided in the applicant’s ER.
If the NRC staff finds that the project meets the PPE and SPE for that Category 1 issue, then
the environmental impact will be considered SMALL for that issue. The NRC defines SMALL
impacts as impacts that are not detectable or are so minor that they will neither destabilize nor
noticeably alter any important attribute of the resource. For the purposes of assessing
radiological impacts, the Commission has concluded that the impacts that do not exceed
permissible levels in the Commission’s regulations are considered SMALL.

22
23
24
25
26
27

For Category 2 issues, the GEIS does not include either PPE or SPE values or assumptions
because a meaningful generic analysis of Category 2 issues is not possible. The applicant will
be required to provide a project-specific analysis for each Category 2 issue in its ER. The
project-specific analysis for a Category 2 issue may lead to a conclusion of SMALL,
MODERATE or LARGE impacts. Because the NRC staff cannot reach a conclusion regarding
the impacts for these issues, the impacts are stated as being “Undetermined” in Table 4-1.

28
29
30
31

For the N/A (Uncertain) issues, the staff will continue to monitor research initiatives to evaluate
the potential human health effects of EMFs. If the NRC finds that the appropriate Federal health
agencies have reached a general agreement on the potential human health effects of exposure
to EMFs, the NRC will determine what to require of all new nuclear reactor license applicants.

32
33
34
35
36
37
38
39

Assumptions including mitigation measures were considered in the analysis of each
environmental issue and are discussed in the appropriate sections of Chapter 3 and are
summarized in Table 4-1. The staff’s generic conclusion for a Category 1 issue may rely on one
or more of the values and assumptions for a parameter. However, the Category 1 issue may not
use all of the values and assumptions for the parameter. To determine which values and
assumptions are applicable to an individual Category 1 issue, the reader should review the
resource-specific evaluation section in Chapter 3.

4-1

Table 4-1
Issue
Land Use
Construction
Onsite Land
Use

Section Category

Finding

PPE/SPE Values and Assumptions

3.1.2.1.1

SMALL

• The proposed project, including any associated land uses, complies with NRC siting regulations in 10 CFR
Part 100 (TN282).
• The site size is 100 ac or less.
• The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and the temporary
footprint of disturbance includes no more than an additional 20 ac or less of vegetated lands.
• The proposed project complies with the site’s zoning and is consistent with any relevant land use plans or
comprehensive plans.
• The site would not be situated closer than 0.5 mi to existing residential areas or 1.0 mi to sensitive land
uses such as Federal, State, or local parks; wildlife refuges; conservation lands; Wild and Scenic Rivers; or
Natural Heritage Rivers.
• The site does not have a history of past industrial use capable of leaving a legacy of contamination
requiring cleanup to protect human health and the environment.
• The total wetland loss from use of the site, including use of any offsite ROWs, would be no more than 0.5
ac.
• BMPs for erosion, sediment control, and stormwater management would be used.
• Compliance with any mitigation measures established through zoning ordinances, local building permits,
site use permits, or other land use authorizations.

3.1.2.1.2

SMALL

• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in width
and total no more than 1 mi in length.
• No new offsite ROW would be situated closer than 0.5 mi to existing residential areas or sensitive land uses
such as Federal, State, or local parks; wildlife refuges; conservation lands; Wild and Scenic Rivers; or
Natural Heritage Rivers.
• No existing ROWs in residential areas would be used or widened to accommodate project features.
• No ROW has a history of past industrial use capable of leaving a legacy of contamination requiring cleanup
to protect human health and the environment.
• The total wetland loss from use of the entire project, including use of the site and any offsite ROWs, would
be no more than 0.5 ac.
• BMPs for erosion, sediment control, and stormwater management would be used.
• Compliance with any mitigation measures established through zoning ordinances, local building permits,
site use permits, or other land use authorizations.

4-2
Offsite Land
Use

Summary of Findings and Mitigation1

For Category 2 issues, the impacts are stated as “Undetermined” because the NRC staff cannot reach a generic conclusion regarding the
impacts for these issues.
1

Table 4-1

Summary of Findings and Mitigation (Continued)

Section Category
3.1.2.1.3
1

Finding
SMALL

Coastal Zone and
Compliance with
the Coastal Zone
Management Act
(16 U.S.C.
§§ 1451 et seq.;
TN1243)
Operation
Onsite Land Use

3.1.2.1.4

SMALL

3.1.2.2.1

SMALL

• The proposed project, including any associated land uses, complies with NRC siting regulations in
10 CFR Part 100.
• The site size is 100 ac or less.
• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in height; and
equipped with drift eliminators.
• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).
• BMPs for erosion, sediment control, and stormwater management would be used.

Offsite Land Use

3.1.2.2.2

SMALL

• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• BMPs for erosion, sediment control, and stormwater management would be used (wherever land is
disturbed during the course of ROW management).

3.2.2.1.1

SMALL

• The site size is 100 ac or less.
• The site would not be situated closer than 0.5 mi to existing residential areas or 1 mi to sensitive
land uses such as Federal, State, or local parks; wildlife refuges; conservation lands; Wild and
Scenic Rivers; or Natural Heritage Rivers.
• The maximum proposed building and structure height is no more than 50 ft, except that the
maximum height is 200 ft for proposed meteorological towers and 100 ft for transmission line
poles/towers and mechanical draft cooling towers.
• The proposed project structures would not be visible from Federal or State parks or wilderness
areas designated as Class 1 under Section 162 of the Clean Air Act (42 U.S.C. § 7472; TN6954); or
as a Wild and Scenic River, a Natural Heritage River, or a river of similar State designation.

3.2.2.1.2

SMALL

• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• No transmission line structures (poles or towers) would be over 100 ft in height.

4-3

Issue
Impacts to Prime
and Unique
Farmland

Visual
Construction
Visual Impacts in
Site and Vicinity

Visual Impacts
from

PPE/SPE Values and Assumptions
• The site size is 100 ac or less.
• The site does not contain any prime or unique farmland or other farmland of statewide or local
importance; or the site does not abut any agricultural land and is not situated in a predominantly
agricultural landscape.
• The site is not situated in any designated coastal zone, or the applicant can demonstrate that the
affected state(s) have or will issue a consistency determination or other indication that the project
complies with the Coastal Zone Management Act.

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• The new offsite ROWs would not be situated closer than 1 mi to existing residential areas or
sensitive land uses such as Federal, State, or local parks; wildlife refuges; conservation lands; Wild
and Scenic Rivers; or Natural Heritage Rivers.
• Any proposed new structures on offsite ROWs would not be visible from Federal or State parks or
wilderness areas designated as Class 1 under Section 162 of the Clean Air Act (42 U.S.C. § 7472;
TN6954); or as a Wild and Scenic River, a Natural Heritage River, or a river of similar State
designation.

Transmission
Lines

3.2.2.2.1

SMALL

• The site would not be situated closer than 1 mi to existing residential areas or sensitive land uses
such as Federal, State, or local parks; wildlife refuges; conservation lands; Wild and Scenic Rivers;
or Natural Heritage Rivers.
• The maximum proposed building and structure height would be no more than 50 ft, except that the
maximum height would be 200 ft for proposed meteorological towers and 100 ft for proposed
transmission line poles/towers and proposed mechanical draft cooling towers.
• The proposed project structures would not be visible from Federal or State parks or wilderness
areas designated as Class 1 under Section 162 of the Clean Air Act (42 U.S.C. § 7472; TN6954); or
as a Wild and Scenic River, a Natural Heritage River, or a river of similar State designation.
• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in height; and
equipped with drift eliminators.
• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).

Air Quality
Construction
Emissions of
Criteria Pollutants
and Dust During
Construction

3.3.2.1.1

SMALL

• The site size is 100 ac or less.
• The permanent footprint of disturbance is 30 ac or less of vegetated lands and the temporary
footprint of disturbance is an additional 20 ac or less of vegetated land.
• New offsite ROWs for transmission lines, pipelines, or access roads would be no longer than 1 mi
and have a maximum ROW width of 100 ft.
• Criteria pollutants emitted from vehicles and standby power equipment during construction are less
than Clean Air Act de minimis levels set by the EPA if the site is located in a nonattainment or
maintenance area, or the site is located in an attainment area.
• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an important
value.
• The LOS determination for affected roadways does not change.
• Mitigation necessary to rely on the generic analysis includes implementation of BMPs for dust
control.
• Compliance with air permits under State and Federal laws that address the impact of air emissions
during construction.

4-4

Operation
Visual Impacts
During
Operations

Table 4-1
Issue
Greenhouse Gas
Emissions During
Construction

Summary of Findings and Mitigation (Continued)

Section
3.3.2.1.2

Category
1

Finding
SMALL

3.3.2.2.1

SMALL

• Criteria pollutants emitted from vehicles and standby power equipment during operations are less
than Clean Air Act de minimis levels set by the EPA if located in a nonattainment or maintenance
area.
• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an important
value.
• The LOS determination for affected roadways does not change.
• The generic analysis can be relied on without applying any mitigation measures.
• Compliance with air permits under State and Federal laws that address the impact of air emissions.
• HAP emissions will be within regulatory limits.

Greenhouse Gas
Emissions During
Operation

3.3.2.2.2

SMALL

• Greenhouse gases emitted by equipment and vehicles during the 97-year GHG life-cycle period
would be equal to or less than 2,534,000 MT of CO2(e). Appendix H of this GEIS contains the staff’s
methodology for developing this value, which includes emissions from construction, operation, and
decommissioning. As long as this total value is met, the impacts for the life-cycle of the project and
the individual phases of the project are determined to be SMALL.

Cooling-System
Emissions

3.3.2.2.3

SMALL

• If needed, cooling towers would be mechanical draft, not natural draft.
• Cooling towers would be equipped with drift eliminators.
• The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an important
value.
• Mechanical draft cooling towers would be less than 100 ft tall.
• Makeup water would be fresh (with a salinity less than 1 ppt).
• Operation of cooling towers is assumed to be subject to State permitting requirements.
• HAP emissions would be within regulatory limits.
• No existing residential areas within 0.5 mi of the site.

Emissions of
Ozone and NOx
during
Transmission
Line Operation
Water Resources
Construction
Surface Water
Use Conflicts

3.3.2.2.4

SMALL

• The transmission line voltage would be no higher than 1,200 kilovolts.

3.4.2.1.1

SMALL

Operation
Emissions of
Criteria and
Hazardous Air
Pollutants during
Operation

PPE/SPE Values and Assumptions
• Greenhouse gases emitted by equipment and vehicles during the 97-year GHG life-cycle period
would be equal to or less than 2,534,000 MT of CO2(e). Appendix H of this GEIS contains the staff’s
methodology for developing this value, which includes emissions from construction, operation, and
decommissioning. As long as this total value is met, the impacts for the life-cycle of the project and
the individual phases of the project are determined to be SMALL.

4-5

Total Plant Water Demand
• Less than or equal to a daily average of 6,000 gpm.

Table 4-1
Issue

Section

Category

Finding

during
Construction

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
If water is obtained from a flowing water body, then the following PPE/SPE parameter and associated
assumptions also apply:
• Average plant water withdrawals do not reduce discharge from the flowing water body by more than 3
percent of the 95 percent exceedance daily flow and do not prevent the maintenance of applicable
instream flow requirements.
• The 95 percent exceedance flow accounts for existing and planned future withdrawals.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.

4-6

If water is obtained from a non-flowing water body, then the following PPE/SPE parameter and
associated value and assumptions also apply:
• Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and intertidal zones
exceeds the amount of water required by the plant.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.
• The Coastal Zone Management Act consistency determination is obtainable, if applicable, for the
non-flowing water body.
Groundwater Use
Conflicts due to
Excavation
Dewatering
Groundwater Use
Conflicts due to
ConstructionRelated
Groundwater
Withdrawals
Water Quality
Degradation due
to ConstructionRelated
Discharges

3.4.2.1.2

SMALL

• The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate may be
larger).
• Dewatering results in negligible groundwater level drawdown at the site boundary.

3.4.2.1.3

SMALL

3.4.2.1.4

SMALL

• The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and the temporary
footprint of disturbance includes no more than an additional 20 ac or less of vegetated lands.
• Adherence to requirements in NPDES permits issued by the EPA or State permitting program, and
any other applicable permits.
• The long-term groundwater dewatering withdrawal rate is less than or equal to 50 gpm.
• Dewatering discharge has minimal effects on the quality of the receiving water body (e.g., as
demonstrated by conformance with NPDES permit requirements).
• There are no planned discharges to the subsurface (by infiltration or injection), including stormwater
discharge.

Table 4-1
Issue
Water Quality
Degradation due
to Inadvertent
Spills during
Construction

Section
3.4.2.1.5

Category
1

Finding
SMALL

Water Quality
Degradation due
to Groundwater
Withdrawal

3.4.2.1.6

SMALL

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• The site size is 100 ac or less.
• The permanent footprint of disturbance includes 30 ac or less of vegetated lands, and the temporary
footprint of disturbance includes no more than an additional 20 ac or less of vegetated lands.
• Applicable requirements and guidance on spill prevention and control are followed, including relevant
BMPs and Integrated Pollution Prevention Plans.
Groundwater Withdrawal for Excavation or Foundation Dewatering
• The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate may be
larger).
• Dewatering results in negligible groundwater level drawdown at the site boundary.
Groundwater Withdrawal for Plant Uses
• Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to 50 gpm.
• Withdrawal results in no more than 1 ft of groundwater level drawdown at the site boundary.
• Withdrawals are not derived from an EPA-designated SSA, or from any aquifer designated by a
State, tribe, or regional authority to have special protections to limit drawdown.
• Withdrawals meet any applicable State or local permit requirements.

4-7

Water Quality
Degradation due
to Offshore or InWater
Construction
Activities

3.4.2.1.7

SMALL

• In-water structures (including intake and discharge structures) are constructed in compliance with
provisions of the CWA Section 404 (33 U.S.C. § 1344; TN1019) and Section 10 of the Rivers and
Harbors Appropriation Act of 1899 (33 U.S.C. §§ 401 et seq.; TN660).
• Adverse effects of building activities controlled and localized using BMPs such as installation of
turbidity curtains or installation of cofferdams.
• Construction duration would be less than 7 years.

Water Use
Conflict Due to
Plant Municipal
Water Demand

3.4.2.1.8

SMALL

Degradation of
Water Quality
from Plant
Effluent
Discharges to
Municipal
Systems
Operation
Surface Water
Use Conflicts
during Operation
due to Water

3.4.2.1.9

SMALL

• The amount available from municipal water systems exceeds the amount of municipal water required
by the plant (gpm).
• Municipal Water Availability accounts for all existing and planned future uses.
• An agreement or permit for the usage amount can be obtained from the municipality.
• Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent accounts for all existing
and reasonably foreseeable future discharges.
• Agreement to discharge to a municipal treatment system is obtainable.

3.4.2.2.1

SMALL

• Total plant water demand is less than or equal to a daily average of 6,000 gpm.
• Average plant water withdrawals do not reduce discharge from the flowing water body by more than 3
percent of the 95 percent exceedance daily flow and do not prevent the maintenance of applicable
instream flow requirements.

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• The 95 percent exceedance flow accounts for existing and planned future withdrawals.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.

Withdrawal from
Flowing
Waterbodies

4-8

Surface Water
Use Conflicts
during Operation
due to Water
Withdrawal from
Non-flowing
Waterbodies

3.4.2.2.2

SMALL

• Total plant water demand is less than or equal to a daily average of 6,000 gpm.
• Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and intertidal zones
exceeds the amount of water required by the plant.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.
• Coastal Zone Management Act of 1972 (16 U.S.C. §§ 1451 et seq.; TN1243) consistency
determination is obtainable, if applicable.

Groundwater Use
Conflicts Due to
Building
Foundation
Dewatering
Groundwater Use
Conflicts Due to
Groundwater
Withdrawals for
Plant Uses

3.4.2.2.3

SMALL

• The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate may be
larger).
• Dewatering results in negligible groundwater level drawdown at the site boundary.

3.4.2.2.4

SMALL

Surface Water
Quality
Degradation Due
to Physical
Effects from
Operation of
Intake and
Discharge
Structures

3.4.2.2.5

SMALL

• Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to 50 gpm.
• Withdrawal results in no more than 1 ft of groundwater level drawdown at the site boundary.
• Withdrawals are not derived from an EPA-designated SSA, or from any aquifer designated by a
State, tribe, or regional authority to have special protections to limit drawdown.
• Withdrawals meet any applicable State or local permit requirements.
• Total plant water demand is less than or equal to a daily average of 6,000 gpm.
• Adhere to best available technology requirements of CWA 316(b) (33 U.S.C. § 1326-TN4823).
• Operated in compliance with CWA Section 316 (b) and 40 CFR 125.83, including compliance with
monitoring and recordkeeping requirements in 40 CFR 125.87 and 40 CFR 125.88, respectively (40
CFR Part 125-TN254).
• Best available technologies are employed in the design and operation of intake and discharge
structures to minimize alterations due to scouring, sediment transport, increased turbidity and
erosion.
• Adherence to requirements in NPDES permits issued by the EPA or a given state.
If water is obtained from a flowing water body, then the following PPE/SPE parameter and associated
value also apply:
• The average rate of plant withdrawal does not exceed 3 percent of the 95 percent exceedance daily
flow for the water body.
If water is obtained from a non-flowing water body, then the following PPE/SPE parameters and
associated values and assumptions also apply:

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and intertidal zones
exceeds the amount of water required by the plant.

Surface Water
Quality
Degradation Due
to Changes in
Salinity Gradients
Resulting from
Withdrawals

3.4.2.2.6

SMALL

• Total plant water demand is less than or equal to a daily average of 6,000 gpm.
If water is obtained from a flowing water body, then the following PPE/SPE parameter and associated
assumptions also apply:
• Average plant water withdrawals do not reduce discharge from the flowing water body by more than 3
percent of the 95 percent exceedance daily flow and do not prevent the maintenance of applicable
instream flow requirements.
• The 95 percent exceedance flow accounts for existing and planned future withdrawals.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.
• If withdrawals are from an estuary or intertidal zone, then changes to salinity gradients are within the
normal tidal or seasonal movements that characterize the water body.

4-9
Surface Water
Quality
Degradation Due
to Chemical and
Thermal
Discharges

3.4.2.2.7

Groundwater
Quality
Degradation Due
to Plant
Discharges

3.4.2.2.8

Water Quality
Degradation due

3.4.2.2.9

If water is obtained from a non-flowing water body, then the following PPE/SPE parameter and
associated values and assumptions also apply:
• Water availability of the Great Lakes, the Gulf of Mexico, oceans, estuaries, and intertidal zones
exceeds the amount of water required by the plant.
• Water availability is demonstrated by the ability to obtain a withdrawal permit issued by State,
regional, or tribal governing authorities.
• Water rights for the withdrawal amount are obtainable, if needed.
• If withdrawals are from an estuary or intertidal zone, then changes to salinity gradients are within the
normal tidal or seasonal movements that characterize the water body.
Undetermined The staff determined that a generic analysis to determine operational impacts on surface water quality
due to chemical and thermal discharges was not possible because (1) some States may impose effluent
constituent limitations more stringent that those required by the EPA, (2) limitations imposed on effluent
constituents may vary among States, and (3) the establishment of a mixing zone may be required.
Because all of these issues related to degradation of surface water quality from chemical and thermal
discharges require consideration of project-specific information, a project-specific assessment should be
performed in the SEIS.
SMALL
• The plant is outside the recharge area for any EPA-designated SSA or any aquifer designated to
have special protections by a State, tribal, or regional authority.
• The plant is outside the wellhead protection area or designated contributing area for any public water
supply well.
• There are no planned discharges to the subsurface (by infiltration or injection).
SMALL
• Applicable requirements and guidance on spill prevention and control are followed, including relevant
BMPs and Integrated Pollution Prevention Plans.

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• There are no planned discharges to the subsurface (by infiltration or injection), including stormwater
discharge.
• A groundwater protection program conforming to NEI 07-07 (NEI 2019-TN6775) is established and
followed.
• The site size is 100 ac or less.
• Use of BMPs for soil erosion, sediment control, and stormwater management.
• Adherence to requirements in NPDES permits issued by the EPA or a given State, and any other
applicable permits.

to Inadvertent
Spills and Leaks
during Operation

3.4.2.2.10

SMALL

• The long-term dewatering withdrawal rate is less than or equal to 50 gpm (the initial rate may be
larger).
• Dewatering results in negligible groundwater level drawdown at the site boundary.
• Groundwater withdrawal for all plant uses (excluding dewatering) is less than or equal to 50 gpm.
• Withdrawal results in no more than 1 ft of groundwater level drawdown at the site boundary.
• Withdrawals are not derived from an EPA-designated SSA, or from any aquifer designated by a
State, tribe, or regional authority to have special protections to limit drawdown.
• Withdrawals meet any applicable State or local permit requirements.

Water Use
3.4.2.2.11
Conflict from
Plant Municipal
Water Demand
Degradation of
3.4.2.2.12
Water Quality
from Plant
Effluent
Discharges to
Municipal
Systems
Terrestrial Ecology
Construction
Permanent and
3.5.2.1.1
Temporary Loss,
Conversion,
Fragmentation,
and Degradation
of Habitats

SMALL

• Usage amount is within the existing capacity of the system(s), accounting for all existing and planned
future uses.
• An agreement or permit for the usage amount can be obtained from the municipality.

SMALL

• Municipal Systems’ Available Capacity to Receive and Treat Plant Effluent accounts for all existing
and reasonably foreseeable future discharges.
• Agreement to discharge to a municipal treatment system is obtainable.

SMALL

• The permanent footprint of disturbance would include 30 ac or less of vegetated lands, and the
temporary footprint of disturbance would include no more than an additional 20 ac or less of
vegetated lands.
• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation once the
lands are no longer needed to support building activities.
• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• The footprint of disturbance (permanent and temporary) would contain no ecologically sensitive
features such as floodplains, shorelines, riparian vegetation, late-successional vegetation, land

Water Quality
Degradation due
to Groundwater
Withdrawals

4-10

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
specifically designated for conservation, or habitat known to be potentially suitable for one or more
Federal or State threatened or endangered species.
• Total wetland impacts from use of the site and any offsite ROWs would be no more than 0.5 ac.
• Applicants would demonstrate an effort to minimize fragmentation of terrestrial habitats by using
existing ROWs, or widening existing ROWs, to the extent practicable.
• BMPs would be used for erosion, sediment control, and stormwater management.

4-11

Permanent and
Temporary Loss
and Degradation
of Wetlands

3.5.2.1.2

SMALL

• Applicant would provide a delineation of potentially impacted wetlands, including wetlands not under
CWA jurisdiction.
• Total wetland impacts from use of the site and any offsite ROWs would be no more than 0.5 ac.
• If activities regulated under the CWA are performed, those activities would receive approval under
one or more NWPs (33 CFR Part 330) or other general permits recognized by the USACE.
• Temporary groundwater withdrawals for excavation or foundation dewatering would not exceed a
long-term rate of 50 gpm.
• Applicants would be able to demonstrate that the temporary groundwater withdrawals would not
substantially alter the hydrology of wetlands connected to the same groundwater resource.
• Any required State or local permits for wetland impacts would be obtained.
• Any mitigation measures indicated in the NWPs or other permits would be implemented.
• BMPs would be used for erosion, sediment control, and stormwater management.

Effects of
Building Noise on
Wildlife
Effects of
Vehicular
Collisions on
Wildlife

3.5.2.1.3

SMALL

• Noise generation would not exceed 85 dBA 50 ft from the source.

3.5.2.1.4

SMALL

• The site size would be 100 ac or less.
• The permanent footprint of disturbance would include 30 ac or less of vegetated lands, and the
temporary footprint of disturbance would include no more than an additional 20 ac or less of
vegetated lands.
• There would be no decreases in the LOS designation for affected roadways.
• The licensee would communicate with Federal and State wildlife agencies and implement mitigation
actions recommended by those agencies to reduce potential for vehicular injury to wildlife.

Bird Collisions
and Injury from
Structures and
Transmission
Lines

3.5.2.1.5

3.5.2.1.6.1

Important
Species and
Habitats –

• The site size would be 100 ac or less.
• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• No transmission line structures (poles or towers) would be more than 100 ft in height.
• Licensees would implement common mitigation measures such as those provided by the American
Bird Conservancy (ABC 2015-TN6763) for buildings, by FWS (2013-TN6764) for towers, and by the
APLIC for transmission lines (APLIC 2012-TN6779).
Undetermined The NRC staff is unable to determine the significance of potential impacts without consideration of
project-specific factors, including the specific species and habitats affected and the types of ecological
changes potentially resulting from each specific licensing action.
SMALL

Table 4-1
Issue

Section

4-12

Resources
Regulated under
the Endangered
Species Act of
1973 (ESA; 16
U.S.C.
§§ 1531 et seq;
TN1010)
Important
3.5.2.1.6.2
Species and
Habitats – Other
Important
Species and
Habitats
Operation
Permanent and
3.5.2.2.1
Temporary Loss
or Disturbance of
Habitats

Summary of Findings and Mitigation (Continued)

Category

Finding

PPE/SPE Values and Assumptions

SMALL

• Applicants would communicate with State natural resource or conservation agencies regarding
wildlife and plants and implement mitigation recommendations of those agencies.

SMALL

• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation once the
lands are no longer needed to support building activities.
• The total wetland loss from site disturbance over the operational life of the plant would be no more
than 0.5 ac.
• Any State or local permits for wetland impacts would be obtained.
• Any mitigation measures indicated in the NWPs or other wetland permits would be implemented.
• BMPs would be used for erosion, sediment control, and stormwater management.

Effects of
Operational
Noise on Wildlife

3.5.2.2.2

SMALL

• Noise generation would not exceed 85 dBA 50 ft from the source.
• There would be no decreases in the LOS designation for affected roadways.
• The licensee would communicate with Federal and State wildlife agencies and implement mitigation
actions recommended by those agencies to reduce potential for vehicular injury to wildlife.

Effects of
Vehicular
Collisions on
Wildlife

3.5.2.2.2

SMALL

Exposure of
Terrestrial
Organisms to
Radionuclides
Cooling-Tower
Operational
Impacts on
Vegetation

3.5.2.2.3

SMALL

• Applicants would demonstrate in their application that any radiological nonhuman biota doses would
be below IAEA (1992-TN712) and NCRP (1991-TN729) guidelines.

3.5.2.2.4

SMALL

Table 4-1

Summary of Findings and Mitigation (Continued)

Section
3.5.2.2.5

Category
1

Finding
SMALL

Bird
Electrocutions
from
Transmission
Lines
Water Use
Conflicts with
Terrestrial
Resources

3.5.2.2.6

SMALL

• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• Common mitigation measures, such as those recommended by APLIC (2006-TN794), would be
implemented.

3.5.2.2.7

SMALL

• Total plant water demand would be less than or equal to a daily average of 6,000 gpm.
• If water is withdrawn from flowing water bodies, average plant water withdrawals would not reduce
flow by more than 3 percent of the 95 percent exceedance daily flow and would not prevent
maintenance of applicable instream flow requirements.
• Any water withdrawals would be in compliance with any EPA or State permitting requirements.
• Applicants would be able to demonstrate that hydroperiod changes are within historical or seasonal
fluctuations.

Effects of
Transmission
Line ROW
Management on
Terrestrial
Resources

3.5.2.2.8

SMALL

• Vegetation in transmission line ROWs would be managed following a plan consisting of integrated
vegetation management practices.
• All ROW maintenance work would be performed in compliance with all applicable laws and
regulations.
• Herbicides would be applied by licensed applicators, and only if in compliance with applicable
manufacturer label instructions.

Effects of
Electromagnetic
Fields on Flora
and Fauna

3.5.2.2.9

4-13

Issue
Bird Collisions
and Injury from
Structures and
Transmission
Lines

Important
3.5.2.2.10.1
Species and
Habitats –
Resources
Regulated under
the ESA of 1973
Important
3.5.2.2.10.2
Species and
Habitats – Other

PPE/SPE Values and Assumptions
• The site size would be 100 ac or less.
• New offsite ROWs for transmission lines, pipelines, or access roads would be no more than 100 ft in
width and total no more than 1 mi in length.
• No transmission line structures (poles or towers) would be more than 100 ft in height.
• Licensees would implement common mitigation measures such as those provided by the American
Bird Conservancy (ABC 2015-TN6763) for buildings, by FWS (2013-TN6764) for towers, and by the
APLIC for transmission lines (APLIC 2012-TN6779).

• Based on the literature review in the License Renewal GEIS, the staff determined that this is a
Category 1 issue and impacts would be SMALL regardless of the length, location, or size of the
transmission lines. The staff did not recommend any mitigation in the License Renewal GEIS (NRC
2024-TN10161); hence, none is needed here. The staff did not rely on any PPE and SPE values or
assumptions in reaching this conclusion.
Undetermined The NRC staff is unable to determine the significance of potential impacts without consideration of
project-specific factors, including the specific species and habitats affected and the types of ecological
changes potentially resulting from each specific licensing action.
SMALL

SMALL

• Applicants would communicate with State natural resource or conservation agencies regarding
wildlife and plants and implement mitigation recommendations of those agencies.

Table 4-1
Issue
Important
Species and
Habitats
Aquatic Ecology
Construction
Runoff and
sedimentation
from construction
areas
Dredging and
filling aquatic
habitats to build
intake and
discharge
structures

4-14

Building
transmission
lines, pipelines,
and access roads
across surface
waterbodies

Section

Category

Finding

3.6.2.1.1

SMALL

3.6.2.1.2

3.6.2.1.3

Important
3.6.2.1.4.1
Species and
Habitats –
Resources
Regulated under
the ESA and
MagnusonStevens Fishery
Conservation and
Management Act

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions

• BMPs would be used for erosion and sediment control.
• Temporarily disturbed lands would be revegetated using regionally indigenous vegetation once the
lands are no longer needed to support building activities.

• Applicant would obtain approval, if required, under NWP 7 in 33 CFR Part 330.
• Applicant would implement any mitigation required under NWP 7 in 33 CFR Part 330.
• Applicant would minimize any temporarily disturbed shoreline and riparian lands needed to build the
intake and discharge structures and restore those areas with regionally indigenous vegetation suited
to those landscape settings once the disturbances are no longer needed.
• BMPs would be used for erosion and sediment control.
SMALL
• If activities regulated under the Clean Water Act are performed, they would receive approval under
one or more NWPs (33 CFR Part 330-TN4318) or other general permits recognized by the USACE.
• Pipelines would be extended under (or over) surface through directional drilling without physically
disturbing shorelines or bottom substrate.
• Access roads would span streams and other surface waterbodies with a bridge or ford, and any fords
would include placement and maintenance of matting to minimize physical disturbance of shorelines
and bottom substrates.
• No access roads would be extended across stream channels over 10 ft in width (at ordinary high
water).
• Any bridges or fords would be removed once no longer needed, and any exposed soils or substrate
would be revegetated using regionally indigenous vegetation appropriate to the landscape setting.
• Any mitigation measures indicated in the NWPs or other permits would be implemented.
• BMPs would be used for erosion and sediment control.
Undetermined The NRC staff is unable to determine the significance of potential impacts without consideration of
project-specific factors, including the specific species and habitats affected and the types of ecological
changes potentially resulting from each specific licensing action. Furthermore, the Endangered Species
Act (16 U.S.C. §§ 1531 et seq.; TN1010) and Magnuson-Stevens Fishery Conservation and
Management Act (16 U.S.C. §§ 1801 et seq.; TN1061) require consultations for each licensing action
that may affect regulated resources.
SMALL

Table 4-1
Issue

Section

(16 U.S.C.
§§ 1801 et seq.;
TN1061)
Important species 3.6.2.1.4.2
and habitats –
Other Important
Species and
Habitats
Operation
Stormwater
3.6.2.2.1
runoff

Summary of Findings and Mitigation (Continued)

Category

Finding

PPE/SPE Values and Assumptions

SMALL

• Applicants would communicate with State natural resource or conservation agencies regarding
aquatic fish, wildlife, and plants and implement mitigation recommendation of those agencies.

SMALL

• Preparation, approval by applicable regulatory agencies, and implementation of a stormwater
management plan.
• Obtaining and compliance with any required permits for the storage and use of hazardous materials
issued by Federal and State agencies under RCRA.
• BMPs would be used for stormwater management.

4-15

Exposure of
aquatic
organisms to
radionuclides
Effects of
refurbishment on
aquatic biota
Effects of
maintenance
dredging on
aquatic biota

3.6.2.2.2

SMALL

• Applicants would demonstrate in their application that any radiological nonhuman biota doses would
be below IAEA (1992-TN712) and NCRP (1991-TN729) guidelines.

3.6.2.2.3

SMALL

• BMPs would be used for erosion, sediment control, and stormwater management.
• Exposed soils would be restored as soon as possible with regionally indigenous vegetation.

3.6.2.2.4

SMALL

• If activities regulated under the Clean Water Act are performed, those activities would receive
approval under one or more NWPs (33 CFR Part 330) or other general permits recognized by the
USACE.
• Any mitigation measures indicated in the NWPs or other permits would be implemented.
• BMPs would be used for erosion and sediment control.

Impacts of
transmission line
ROW
management on
aquatic resources

3.6.2.2.5

SMALL

Impingement and
entrainment of
aquatic
organisms

3.6.2.2.6

SMALL

• Intakes would comply with regulatory requirements established by EPA in 40 CFR 125.84 (TN254) to
be protective of fish and shellfish.
• Best available control technology would be employed in the design of intakes to minimize
entrainment and impingement, such as use of screens and intake rates recognized to minimize
effects.

Table 4-1
Issue
Thermal impacts
on aquatic biota

Section
3.6.2.2.7

Other effects of
cooling-water
discharges on
aquatic biota
Water use
conflicts with
aquatic resources

3.6.2.2.8

Category
Finding
PPE/SPE Values and Assumptions
2
Undetermined Staff would have to first review the discharge plume analysis (as described in Section 3.4) and the
aquatic biota potentially present before being able to reach a conclusion regarding the possible
significance of impacts to that biota.
2
Undetermined Staff would have to first review the discharge plume analysis (as described in Section 3.4) and the
aquatic biota potentially present before being able to reach a conclusion regarding the possible
significance of impacts to that biota.

3.6.2.2.9

4-16

Important
3.6.2.2.10.1
Species and
Habitats –
Resources
Regulated under
the ESA and
MagnusonStevens Act
Important species 3.6.2.2.10.2
and habitats –
Other Important
Species and
Habitats
Historic and Cultural Resources
Construction
Construction
3.7.2
impacts on
historic and
cultural resources
Operation

Summary of Findings and Mitigation (Continued)

• If needed, cooling towers would be mechanical draft, not natural draft; less than 100 ft in height; and
equipped with drift eliminators.
• Any makeup water for the cooling towers would be fresh water (less than 1 ppt salinity).
• Total plant water demand would be less than or equal to a daily average of 6,000 gpm.
• If water is withdrawn from flowing waterbodies, average plant water withdrawals would not reduce
flow by more than 3 percent of the 95 percent exceedance daily flow, and would not prevent
maintenance of applicable instream flow requirements.
• Any water withdrawals would be in compliance with any EPA or State permitting requirements.
• Applicants would be able to demonstrate that hydroperiod changes are within historical or seasonal
fluctuations.
Undetermined The NRC staff is unable to determine the significance of potential impacts without consideration of
project-specific factors, including the specific species and habitats affected and the types of ecological
changes potentially resulting from each specific licensing action. Furthermore, the Endangered Species
Act (16 U.S.C. §§ 1531 et seq.; TN1010) and Magnuson-Stevens Fishery Conservation and
Management Act (16 U.S.C. §§ 1801 et seq.; TN1061) require consultations for each licensing action
that may affect regulated resources.
SMALL

SMALL

• Applicants would communicate with State natural resource or conservation agencies regarding
aquatic fish, wildlife, and plants and implement mitigation recommendations of those agencies.

Undetermined Impacts on historic and cultural resources are analyzed on a project-specific basis. The NRC will
perform National Environmental Policy Act (NEPA) and NHPA Section 106 analysis, in accordance with
36 CFR Part 800, in its preparation of the SEIS. The NHPA Section 106 analysis includes consultation
with the State and Tribal Historic Preservation Officers, American Indian Tribes, and other interested
parties.

Table 4-1
Issue
Section
Operation
3.7.2
impacts on
historic and
cultural resources
Radiological Environment
Construction
Radiological dose 3.8.1.2.1
to construction
workers

Category
Finding
PPE/SPE Values and Assumptions
2
Undetermined Impacts on historic and cultural resources are analyzed on a project-specific basis. The NRC will
perform NEPA and NHPA Section 106 analysis, in accordance with 36 CFR Part 800, in its preparation
of the SEIS. The NHPA Section 106 analysis includes consultation with the State and Tribal Historic
Preservation Officers, American Indian Tribes, and other interested parties.

SMALL

• For protection against radiation, the applicant must meet the regulatory requirements of:
- 10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a license
- 10 CFR 20.1201 Occupational dose limits for adults
- 10 CFR 20.1301 Dose limits for individual members of the public
- Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs) and Derived Air Concentrations
(DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for
Release to Sewerage
- 10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control releases of
radioactive material in effluents—nuclear power reactors
- 10 CFR 50.36a Technical specifications on effluents from nuclear power reactors
- Application contains sufficient technical information for the staff to complete the detailed
technical safety review.
- Application will be found to be in compliance by the staff with the above regulations through a
radiation protection program and an effluent release monitoring program.

SMALL

• For protection against radiation, the applicant must meet the regulatory requirements of:
− 10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a license
− 10 CFR 20.1201 Occupational dose limits for adults
− Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs) and Derived Air Concentrations
(DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for
Release to Sewerage
− 10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control releases of
radioactive material in effluents—nuclear power reactors
− 10 CFR 50.36a Technical specifications on effluents from nuclear power reactors
• Application contains sufficient technical information for the staff to complete the detailed technical
safety review
• Application will be found to be in compliance by the staff with the above regulations through a
radiation protection program and an effluent release monitoring program.

SMALL

4-17
Operation
Occupational
3.8.1.2.2.1
doses to workers

Maximally
exposed
individual annual
doses

3.8.1.2.2.2

Summary of Findings and Mitigation (Continued)

Table 4-1
Issue

Section

Category

Summary of Findings and Mitigation (Continued)

Finding

PPE/SPE Values and Assumptions

•
•
Total population
annual doses

3.8.1.2.2.3

SMALL

•

4-18

•
•
Nonhuman biota
doses

3.8.1.2.2.4

Nonradiological Environment
Construction
Building impacts
3.8.2.2.1
of chemical,
biological, and
physical
nonradiological
hazards
Building impacts
3.8.2.2.1
of EMFs

− Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs) and Derived Air Concentrations
(DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for
Release to Sewerage
− 10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control releases of
radioactive material in effluents—nuclear power reactors
− 10 CFR 50.36a Technical specifications on effluents from nuclear power reactors
Application contains sufficient technical information for the staff to complete the detailed technical
safety review
Application will be found to be in compliance by the staff with the above regulations through a
radiation protection program and an effluent release monitoring program
For protection against radiation, the applicant must meet the regulatory requirements of:
− 10 CFR 20.1101 Radiation Protection Programs (10 CFR Part 20-TN283) if issued a license
− 10 CFR 20.1301 Dose limits for individual members of the public
− Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs) and Derived Air Concentrations
(DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for
Release to Sewerage
− 10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for equipment to control releases of
radioactive material in effluents—nuclear power reactors
− 10 CFR 50.36a Technical specifications on effluents from nuclear power reactors
Application contains sufficient technical information for the staff to complete the detailed technical
safety review
Application will be found to be in compliance by the staff with the above regulations through a
radiation protection program and an effluent release monitoring program.

SMALL

• Applicants would demonstrate in their application that any radiological nonhuman biota doses would
be below IAEA (1992-TN712) and NCRP (1991-TN729) guidelines.

SMALL

• The applicant must adhere to all applicable Federal, State, local or Tribal regulatory limits and permit
conditions for chemical hazards, biological hazards, and physical hazards.
• The applicant will follow nonradiological public and occupational health BMPs and mitigation
measures, as appropriate.

N/A

Uncertain

Studies of 60 Hz EMFs have not uncovered consistent evidence linking harmful effects with field
exposures. Because the state of the science is currently inadequate, no generic conclusion on human
health impacts is possible. If, in the future, the Commission finds that a general agreement has been
reached by appropriate Federal health agencies that there are adverse health effects from EMFs, the
Commission will require applicants to submit plant-specific reviews of these health effects as part of their
application. Until such time, applicants are not required to submit information about this issue.

Table 4-1
Issue
Operation
Operation
impacts of
chemical,
biological, and
physical
nonradiological
hazards
Operation
impacts of EMFs

4-19

Noise
Construction
Constructionrelated noise

Operation
Operation-related
noise

Summary of Findings and Mitigation (Continued)

Section

Category

Finding

PPE/SPE Values and Assumptions

3.8.2.2.2

SMALL

3.8.2.2.2

N/A

Uncertain

Studies of 60 Hz EMFs have not uncovered consistent evidence linking harmful effects with field
exposures. Because the state of the science is currently inadequate, no generic conclusion on human
health impacts is possible. If, in the future, the Commission finds that a general agreement has been
reached by appropriate Federal health agencies that there are adverse health effects from EMFs, the
Commission will require applicants to submit plant-specific reviews of these health effects as part of their
application. Until such time, applicants are not required to submit information about this issue.

3.9.2.1

SMALL

• The noise level would be no more than 65 dBA at site boundary, unless a relevant State or local
noise abatement law or ordinance sets a different threshold, which would then be the presumptive
threshold for PPE purposes.
• If an applicant cannot meet the 65 dBA threshold through mitigation, then the applicant must obtain a
various or exception with the relevant State or local regulator.
• The project would implement BMPs, including such as modeling, foliage planting, construction of
noise buffers, and the timing of construction and/or operation activities.

3.9.2.2

SMALL

• Applicants must meet the regulatory requirements of 10 CFR Part 20 (TN283) (e.g., 20.1406 and
Subpart K), 10 CFR Part 61 (TN252), 10 CFR Part 71 (TN301), and 10 CFR Part 72 (TN4884).
• Quantities of LLRW generated at a new nuclear reactor would be less than the quantities of LLRW
generated at existing nuclear power plants, which generate an average of 21,200 ft3 (600 m3) and

Radiological Waste Management
Operation
LLRW
3.10.1.2.1

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
2,000 Ci (7.4 × 1013 Bq) per year for boiling water reactors and half that amount for pressurized water
reactors (NRC 2024-TN10161).

Onsite spent
nuclear fuel
management
Mixed waste

3.10.1.2.2

SMALL

• Compliance with 10 CFR Part 72 (TN4884)

3.10.1.2.3

4-20

SMALL

• RCRA Small Quantity Generator (EPA 2020-TN6590) for Mixed Waste.

Nonradiological Waste Management
Construction
Construction
3.10.2.2.1
1
nonradiological
waste

SMALL

• The applicant must meet all the applicable permit conditions, regulations, and BMPs related to solid,
liquid, and gaseous waste management.
• For hazardous waste generation, applicants must meet conformity with hazardous waste quantity
generation levels in accordance with RCRA.
• For sanitary waste, applicants must dispose of sanitary waste in a permitted process.
• For mitigation measures, the applicant would perform mitigation measures to the extent practicable,
such as recycling, process improvements, or the use of a less hazardous substance.

Operation
Operation
nonradiological
waste

SMALL

• For the exclusion area boundary, the maximum TEDE for any 2-hour period during the radioactivity
release should be calculated.
• For the low-population zone, the TEDE should be calculated for the duration of the accident release
(i.e., 30 days, or other duration as justified).

3.10.2.2.2

Postulated Accidents
Operation
Design Basis
3.11.2.1
Accidents
Involving
Radiological
Releases

The above calculations would compare the DBA doses with the dose criteria given in regulations related
to the application (e.g., 10 CFR 50.34(a)(1) [TN249], 10 CFR 52.17(a)(1) and 10 CFR 52.79(a)(1) [10
CFR Part 52-TN251]), standard review plans (e.g., SRP criteria, Table 1 in SRP Section 15.0.3 of
NUREG-0800 [NRC 2007/2019-TN6221]), and RGs, (e.g., RG 1.183 [NRC 2000-TN517]), as applicable.
Accidents
Involving
Releases of

3.11.2.2

SMALL

• Reactor inventory of a regulated substance is less than its TQ. TQs are found in 40 CFR 68.130,
Tables 1, 2, 3, and 4 (TN5494); and

Table 4-1
Issue

Section

Category

Hazardous
Chemicals

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions

• Reactor inventory of an EHS is less than its TPQ. TPQs are found in 40 CFR Part 355, Appendices A
and B (TN5493).
Undetermined Based on the analysis in the Final Safety Analysis Report/Preliminary Safety Analysis Report regarding
severe accidents, if a reactor design has severe accident progressions with radiological or hazardous
chemical releases, then an environmental risk evaluation must be performed.
SMALL
If a cost-screening analysis determines that the maximum benefit for avoiding an accident is so small
that a SAMDA analysis is not justified based on a minimum cost to design an appropriate SAMDA.

Severe Accidents

3.11.2.3

Severe Accident
Mitigation Design
Alternatives
Acts of Terrorism

3.11.2.4

3.11.2.5

SMALL

The environmental impacts of acts of terrorism and sabotage only need to be addressed if a reactor
facility is subject to the jurisdiction of the U.S. Court of Appeals for the Ninth Circuit.

3.12.1.1.1

SMALL

Transportation
Systems and
Traffic

3.12.1.1.2

SMALL

Economic
Impacts

3.12.1.1.3

Beneficial

Tax Revenue
Impacts

3.12.1.1.4

Beneficial

• The housing vacancy rate in the affected economic region does not change by more than 5 percent,
or at least 5 percent of the housing stock remains available after accounting for in-migrating
construction workers.
• Student:teacher ratios in the affected economic region do not exceed locally mandated levels after
including the school age children of the in-migrating worker families.
The LOS determination for affected roadways does not change. Mitigation measures may include
implementation of traffic flow management, management of shift-change timing, and encouragement of
ride-sharing and use of public transportation options, such that LOS values can be maintained with the
increased volumes.
The economic impacts of construction and operation of a new nuclear reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental review, the
NRC staff determines a detailed analysis of economic costs and benefits is needed for analysis of the
range of alternatives considered or relevant to mitigation, the staff may require further information from
the applicant.
The tax revenue impacts of construction and operation of a new nuclear reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental review, the
NRC staff determines a detailed analysis of tax revenue costs and benefits is needed for analysis of the
range of alternatives considered or relevant to mitigation, the staff may require further information from
the applicant.

3.12.1.2.1

SMALL

Socioeconomics
Construction
Community
Services and
Infrastructure

4-21

Operation
Community
Services and
Infrastructure

Table 4-1
Issue
Transportation
Systems and
Traffic

Section Category
3.12.1.2.2
1

Finding
SMALL

Economic
Impacts

3.12.1.2.3

Beneficial

Tax Revenue
Impacts

3.12.1.2.4

Beneficial

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
The LOS determination for affected roadways does not change. Mitigation measures may include
implementation of traffic flow management, management of shift-change timing, and encouragement of
ride-sharing and use of public transportation options, such that LOS values can be maintained with the
increased volumes.
The economic impacts of construction and operation of a new nuclear reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental review, the
NRC staff determines a detailed analysis of economic costs and benefits is needed for analysis of the
range of alternatives considered or relevant to mitigation, the staff may require further information from
the applicant.
The tax revenue impacts of construction and operation of a new nuclear reactor are expected to be
beneficial; therefore, this is a Category 1 issue. If, during the project-specific environmental review, the
NRC staff a detailed analysis of tax revenue costs and benefits is needed for analysis of the range of
alternatives considered or relevant to mitigation, the staff may require further information from the
applicant.

4-22

Environmental Justice
Construction
Construction
3.13.2.1
Environmental
Justice Impacts

Undetermined Project-specific analysis would be necessary, including analysis of the presence and size of specific
minority or low-income populations, impact pathways derived from the plant design, layout, or site
characteristics, or other community characteristics affecting specific minority or low-income populations.
In performing its environmental justice analysis, the NRC staff will be guided by the NRC’s “Policy
Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing
Actions,” which was published in the Federal Register on August 24, 2004 (69 FR 52040-TN1009).

Operation
Operation
Environmental
Justice Impacts

3.13.2.1

Table 4-1
Issue
Fuel Cycle
Operation
Uranium
Recovery

Summary of Findings and Mitigation (Continued)

Category

Finding

PPE/SPE Values and Assumptions

3.14.2.1

SMALL

• Table S–3 is expected to bound the impacts for new nuclear reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:
− Increasing use of in situ leach uranium mining has lower environmental impacts than traditional
mining and milling methods.
− Current light-water reactors are using nuclear fuel more efficiently due to higher levels of fuel
burnup resulting in less demand for mining and milling activities.
− Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting mining and milling activities.
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material and 10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive Material.

Uranium
Conversion

3.14.2.2

SMALL

• Table S–3 is expected to bound the impacts for new nuclear reactor fuels because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:
− Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup resulting in
less demand for conversion activities.
− Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting conversion activities.
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material and 10 CFR Part 71 (TN301), Packaging and Transportation of Radioactive Material, and 10
CFR Part 73 (TN423), Physical Protection of Plants and Materials.

Enrichment

3.14.2.3

SMALL

• Table S–3 is expected to bound the impacts for new nuclear reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:
• Transitioning of U.S. uranium enrichment technology from gaseous diffusion to gas centrifugation,
which requires less electrical usage per separative work unit.
• Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup resulting in
less demand for enrichment activities.
• Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting enrichment activities.
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material, 10 CFR Part 70 (TN4883), Domestic Licensing of Special Nuclear Material, 10 CFR Part 71
(TN301), Packaging and Transportation of Radioactive Material, and 10 CFR Part 73 (TN423),
Physical Protection of Plants and Materials.

Fuel
Fabrication(a)

3.14.2.4

SMALL

4-23

Section

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
− Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting fabrication.
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material, 10 CFR Part 70 (TN4883), Domestic Licensing of Special Nuclear Material, 10 CFR Part 71
(TN301), Packaging and Transportation of Radioactive Material, and 10 CFR Part 73 (TN423),
Physical Protection of Plants and Materials.

3.14.2.5

SMALL

• Table S–3 is expected to bound the impacts for new nuclear reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:
− Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup resulting in
fewer discharged fuel assemblies to be reprocessed each year.
− Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting reprocessing.
• Reprocessing capacity up to 900 MTU/yr
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material, 10 CFR Part 50 (TN249) Domestic Licensing of Production and Utilization Facilities,10 CFR
Part 70 (TN4883), Domestic Licensing of Special Nuclear Material, 10 CFR Part 71 (TN301),
Packaging and Transportation of Radioactive Material, 10 CFR Part 72 (TN4884), Licensing
Requirements for the Independent Storage of Spent Fuel, High-Level Radioactive Waste, and
Reactor-related Greater Than Class C Waste, and 10 CFR Part 73 (TN423), Physical Protection of
Plants and Materials.

Storage and
Disposal of
Radiological
Wastes

3.14.2.6

SMALL

• Table S–3 is expected to bound the impacts for new nuclear reactor fuels, because of uranium fuel
cycle changes since WASH-1248 (AEC 1974-TN23), including:
− Current LWRs are using nuclear fuel more efficiently due to higher levels of fuel burnup resulting in
fewer discharged fuel assemblies to be stored and disposed.
− Less reliance on coal-fired electrical generation plants is resulting in less gaseous effluent releases
from electrical generation sources supporting storage and disposal.
• Waste and spent fuel inventories, as well as their associated certified spent fuel shipping and storage
containers, are not significantly different from what has been considered for LWR evaluations in
NUREG-2157 (NRC 2014-TN4117).
• Must satisfy the regulatory requirements of 10 CFR Part 40 (TN4882) Domestic Licensing of Source
Material, 10 CFR Part 70 (TN4883), Domestic Licensing of Special Nuclear Material, 10 CFR Part 71
(TN301), Packaging and Transportation of Radioactive Material, 10 CFR Part 72 (TN4884), Licensing
Requirements for the Independent Storage of Spent Fuel, High-Level Radioactive Waste, and
Reactor-related Greater Than Class C Waste, and 10 CFR Part 73 (TN423), Physical Protection of
Plants and Materials.

4-24

Reprocessing

Table 4-1

Summary of Findings and Mitigation (Continued)

Finding

PPE/SPE Values and Assumptions

SMALL

Transportation of
Radioactive
Waste

3.15.2.2

SMALL

• The maximum annual one-way shipment distance (59,160 km) presented in Table 3-11. The annual
shipments associated with the one-way shipment distance have been normalized to a net electrical
output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor from WASH-1238 (AEC
1972-TN22).
• The maximum annual round-trip shipment distance (118,320 km) presented in Table 3-12. The
annual shipments associated with the round-trip shipment distance have been normalized to a net
electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor from WASH-1238
(AEC 1972-TN22).
• The maximum annual round-trip shipment distance (293,145 km) presented in Table 3-16. The
annual shipments associated with the round-trip shipment distance have been normalized to a net
electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a shipment
volume of 2.34 m3/shipment from WASH-1238 (AEC 1972-TN22).

Transportation of
Irradiated Fuel

3.15.2.3

SMALL

• The maximum annual one-way shipment distance (505,393 km) presented in Table 3-17. The annual
shipments associated with the one-way shipment distance have been normalized to a net electrical
output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a shipment capacity of
0.5 MTU/shipment from WASH-1238 (AEC 1972-TN22).
• The maximum annual round-trip shipment distance (1,010,786 km) presented in Table 3-19. The
annual shipments associated with the round-trip shipment distance have been normalized to a net
electrical output of 880 MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor and a shipment
capacity of 0.5 MTU/shipment from WASH-1238 (AEC 1972-TN22).
• A maximum peak rod burnup of 62 GWd/MTU for UO 2 fuel and peak pellet burnup of 133 GWd/MTU
for TRISO fuel (see Table 3-18).

3.16.2

SMALL

The environmental impacts for the following resource areas were generically addressed in NUREG0586, Supplement 1, would be limited to operational areas, would not be detectable or destabilizing and
are expected to have a negligible effect on the impacts of terminating operations and decommissioning:

4-25

Issue
Section Category
Transportation of Fuel and Waste
Operation
Transportation of 3.15.2.1
1
Unirradiated Fuel

Decommissioning
Decommissioning

Table 4-1
Issue

Section

Category

Summary of Findings and Mitigation (Continued)

Finding

PPE/SPE Values and Assumptions
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

4-26
Decommissioning

3.16.2

Onsite land use
Water use
Water quality
Air quality
Aquatic ecology within the operational area
Terrestrial ecology within the operational area
Radiological
Radiological accidents (non-spent-fuel-related)
Occupational issues
Socioeconomic
Onsite cultural and historic resources for plants where the disturbance of lands beyond the
operational areas is not anticipated
Aesthetics
Noise
Transportation
Irretrievable resource

The following issues were not addressed in NUREG-0586, Supplement 1, but have been determined to
be Category 1 issues:
• Nonradiological waste
• Greenhouse gases
Undetermined The following two issues were identified in NUREG-0586, Supplement 1, as requiring a project-specific
review:
• Environmental justice
• Threatened and endangered species
Four conditionally project-specific issues identified in NUREG-0586, Supplement 1, will require a projectspecific review if present:
• Land use involving offsite areas to support decommissioning activities
• Aquatic ecology for activities beyond the licensed operational area
• Terrestrial ecology for activities beyond the licensed operational area
• Historic and cultural resources (archaeological, architectural, structural, historic) for activities within
and beyond the licensed operational area with no current (i.e., at the time of decommissioning)
evaluation of resources for NRHP eligibility
Additionally, the following two environmental resource areas are additional decommissioning impacts
that require project-specific review:

Table 4-1
Issue

Section

Category

Finding

Summary of Findings and Mitigation (Continued)
PPE/SPE Values and Assumptions
• Climate change: the effects of climate change are location-specific and cannot, therefore, be
evaluated generically (see Section 1.3.3.2.2, Category 2 Issues Applying Across Resources, of this
NR GEIS)
• Cumulative effects: must be considered on a project-specific basis where impacts would depend on
regional resource characteristics, the resource specific impacts of the project, and the cumulative
significance of other factors affecting the resource. (see Section 1.3.3.2.2, Category 2 Issues
Applying Across Resources, of this NR GEIS)

Issues Applying Across All Resources
Climate Change
1.3.3.2.2
2

Cumulative
Impacts

1.3.2.2.2

4-27

Undetermined The effects of climate change are location-specific and cannot, therefore, be evaluated generically. For
example, while climate change may cause many areas to receive less than average annual precipitation,
other areas may see an increase in average annual precipitation. Therefore, applicants and staff would
address the effects of climate change in the environmental documents for new nuclear reactor licensing.
Undetermined Applications must individually consider the cumulative impacts from past, present, and reasonably
foreseeable future actions known to occur at specific sites for proposed new nuclear reactors, and briefly
present those considerations in supplemental NEPA documentation. The staff would explain whether
these individualized evaluations of potential cumulative impacts alter any of the generic analyses and
conclusions relied upon for Category 1 issues. The individualized cumulative impact analyses may also
identify opportunities where staff might rely upon the generic analyses for some Category 1 issues for
which certain of the PPE or SPE values and assumptions might be exceeded.

Non-Resource Related Issues
Purpose and
1.3.3.2.3
2
Undetermined Must be described in the environmental report associated with a given application.
Need
Need for Power
1.3.3.2.3
2
Undetermined Must be described in the environmental report associated with a given application.
Site Alternatives
1.3.3.2.3
2
Undetermined Must be described in the environmental report associated with a given application.
Energy
1.3.3.2.3
2
Undetermined Must be described in the environmental report associated with a given application.
Alternatives
System Design
1.3.3.2.3
2
Undetermined Must be described in the environmental report associated with a given application.
Alternatives
(a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the staff’s generic analysis.

1
2

4.1

Unavoidable Adverse Environmental Impacts and Irreversible and
Irretrievable Commitments of Resources

3
4
5
6
7
8

Unavoidable adverse environmental impacts are those potential impacts of the NRC proposed
action that cannot be avoided and for which no practical means of mitigation are available. The
term “irreversible and irretrievable commitments of resources” refers to environmental resources
that would be irreparably changed by the activities authorized by the NRC, where the
environmental resources could not be restored at some later time to the resource’s state before
the relevant activities.

9
10
11
12

Because the issuance of the NR GEIS would itself have no impacts and would not approve or
license the construction and/or operation of any new nuclear reactor, there would be no
unavoidable adverse environmental impacts or any irreversible or irretrievable commitments of
resources from development of the NR GEIS.

13
14
15
16
17

Any project-specific SEIS developed for a proposed new nuclear reactor tiering to the GEIS
would be required to analyze the impacts associated with construction and operation of such a
facility. The unavoidable adverse environmental impacts associated with the granting of the
license would include impacts of construction, preconstruction, and operation and would be
described in the project-specific SEIS.

18
19
20
21
22
23
24

The irreversible and irretrievable commitments of resources during construction of the proposed
new nuclear reactor generally would be similar to those of any major construction project and
would be dependent on the size and scale of the proposed reactor. The NRC would prepare the
project-specific SEIS, issue the requisite record of decision in accordance with 10 CFR 51.102
(TN250), and assuming approval of the project, describe any such irreversible and irretrievable
commitments of resources in the SEIS before the issuance of any license, permit, or other
authorization to construct or operate a new nuclear reactor.

25
26
27
28
29
30
31
32
33
34
35

The NRC staff expects that the use of construction materials in the quantities associated with
those expected for new nuclear reactors tiering to the GEIS, while irreversible and irretrievable,
would be of small consequence with respect to the availability of such resources. The main
resource that would be irreversibly and irretrievably committed during operation of any new
nuclear unit would be the fuel. If uranium is the fuel, the availability of uranium ore and existing
stockpiles of highly enriched uranium in the United States and Russia that could be processed
into fuel is sufficient (OECD/NEA and IAEA 2008-TN3992) so that the irreversible and
irretrievable commitment of this resource would be negligible. The irreversible and irretrievable
commitment of resources would not be the same for all nuclear power plants and would depend
on the specific characteristics of the power plant (e.g., thorium fuel cycle, lithium-based primary
fluid, or other resource characteristic) and its resource needs.

36
37

4.2

38
39
40

NEPA Section 102(2)(C)(iv) (42 U.S.C. § 4332(C)(iv); TN4880) requires that an EIS include
information about the relationship between local short-term uses of the environment and the
maintenance and enhancement of long-term productivity.

41
42
43

Because the issuance of the NR GEIS would not approve or license the construction and/or
operation of any new nuclear reactor, the GEIS itself would not result in either short-term or
long-term impacts. However, a project-specific SEIS tiering to the GEIS would consider the

Relationship between Short-Term Use of the Environment and Long-Term
Productivity

4-28

1
2

relationship between local short-term uses of the environment and the maintenance and
enhancement of long-term productivity.

3
4
5
6
7

Nuclear power plant construction and operations would necessitate short-term use of the
environment and commitments of resources. Certain resources (e.g., land and energy) will be
committed indefinitely or permanently. Short-term use of the environment can affect long-term
productivity of the ecosystem if that use alters the ability of the ecosystem to re-establish an
equilibrium that is comparable to that of its original condition.

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

Air emissions from power plant operations would introduce small amounts of radiological and
nonradiological constituents to the region around the plant site. Over time, these emissions
could result in increased concentrations and exposure, but are not expected to affect air quality
or radiation exposure to the extent that public health and long-term productivity of the
environment would be impaired. Continued employment, expenditures, and tax revenues
generated during power plant operations would directly benefit local, regional, and State
economies during the short term. Local governments investing project-generated tax revenues
into infrastructure and other required services could enhance economic productivity over the
long term. The management and disposal of spent nuclear fuel, low-level waste, hazardous
waste, and nonhazardous waste would require an increase in energy and would consume
space at treatment, storage, or disposal facilities. Regardless of the location, the use of land to
meet waste disposal needs would reduce the long-term productivity of the land. Power plant
facilities would be committed to power production over the short term. After decommissioning
these facilities and restoring the power plant site, the land would become available for other
productive uses. The nature of the relationship between short-term use of the environment and
long-term productivity would vary among plants and would depend on the specific
characteristics of each plant and its interaction with the environment. This relationship is
reactor-specific and would be analyzed in a project-specific SEIS.

4.3

27
28
29
30
31
32
33

Under the No-Action Alternative the NRC would not issue this GEIS. There are no
environmental impacts associated with not issuing the GEIS. In this context, the No-Action
Alternative would accomplish none of the benefits intended by the GEIS process, which would
include (1) reducing the time and resources for the applicant’s preparation of the ER,
(2) reducing the time and resources for the NRC staff’s preparation of the EIS, and (3) focusing
the effort of applicant, NRC staff, and decision-makers on issues that involve a potential for
significant environmental impacts.

34
35
36
37
38
39

Selection of the No-Action Alternative would likely lead to the same magnitude and level of
environmental impacts associated with the licensing of new nuclear reactors; these impacts
would be addressed in project-specific EISs rather than in supplemental analyses tiering to the
NR GEIS. Mitigation measures associated with these projects would be developed on a caseby-case basis rather than comprehensively, as in the GEIS, potentially leading to increased
inconsistency and potential greater impacts.

4.4

41
42
43

Section 102(B) of NEPA requires that all Federal agencies “identify and develop methods and
procedures, in consultation with the Council on Environmental Quality established by Title II of
this Act, which will ensure that presently unquantified environmental amenities and values

No-Action Alternative Conclusion

Cost Benefit

4-29

1
2

may be given appropriate consideration in decision-making along with economic and
technical considerations” (42 U.S.C. § 4332(B); TN4880).

3
4
5
6
7
8
9
10

However, neither NEPA nor the government-wide NEPA-implementing regulations of the
Council on Environmental Quality require the benefits and costs of a proposed action be
quantified in dollars or any other common metric. The intent of this section is not to identify and
quantify all of the potential societal benefits of the proposed activities and compare them to the
potential costs of the proposed activities. Instead, this section focuses on only the benefits and
costs of such magnitude or importance that their inclusion in this analysis can inform the
decision-making process. This section summarizes the pertinent analytical conclusions reached
in earlier chapters of this GEIS.

11
12
13
14
15
16
17
18
19
20
21

The proposed action of proceeding with the GEIS is expected to improve the efficiency of the
environmental review process and avoid duplication of effort, compared to the No-Action
Alternative of developing individual project-specific EISs for new nuclear reactor applications.
The issues identified as Category 1 in this GEIS have been analyzed and resolved generically;
therefore, the resources needed for subsequent staff reviews of environmental issues in
individual new nuclear reactor applications would be reduced. In addition, by analyzing
Category 1 issues generically, the GEIS would also enhance consistency across environmental
reviews, thereby increasing efficiency and streamlining the environmental review process. Use
of the GEIS would allow NRC staff and decision-makers to focus on issues that involve a
potential for significant environmental impacts. Project-specific environmental reviews would be
able to incorporate the GEIS findings by reference, thereby streamlining the review processes.

4-30

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Manufacturing Branch Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Materials
Safety and Safeguards, to D.W. Johnson, Director, Office of Technical Programs and
Coordination Activities, Department of Labor Occupational Safety and Health Administration,
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NRC (U.S. Nuclear Regulatory Commission). 2014. Attachment 1: Staff Guidance for
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NRC (U.S. Nuclear Regulatory Commission). 2016. Environmental Impact Statement for
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NRC (U.S. Nuclear Regulatory Commission). 2017. Aquatic Environmental Studies for Nuclear
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NRC (U.S. Nuclear Regulatory Commission). 2018. Certificate of Compliance for Radioactive
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NRC (U.S. Nuclear Regulatory Commission). 2019. Certificate of Compliance for Radioactive
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Material Packages, Certificate Number 9372, Revision 2. Washington, D.C. ADAMS Accession
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NRC (U.S. Nuclear Regulatory Commission). 2019. Environmental Assessment for the
Proposed Renewal of Source Material License SUB–526 Metropolis Works Uranium Conversion
Facility (Massac County, Illinois). Washington, D.C. ADAMS Accession No. ML19273A012.
TN6964.

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NRC (U.S. Nuclear Regulatory Commission). 2019. Environmental Assessment for the Renewal
of SNM-1107 Columbia Fuel Fabrication Facility in Richland County, South Carolina. Draft for
Comment, Westinghouse Electric Company, LLC, Hopkins, South Carolina. ADAMS Accession
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with Micro-Reactors. Draft Interim Staff Guidance, COL-ISG-029, Washington, D.C. ADAMS
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NRC (U.S. Nuclear Regulatory Commission). 2019. Generic Environmental Impact Statement
for License Renewal of Nuclear Plants, Supplement 5, Second Renewal, Regarding
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Waste.” Washington, D.C. ADAMS Accession No. ML21145A383. TN6440.

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Barrasso, dated July 29, 2019, regarding “Response to Request that NRC Initiate a Process to
Develop a Generic Environmental Impact Statement for the Construction and Operation of
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11
12

WHO (World Health Organization). 2020. “What are Electromagnetic Fields?” Geneva,
Switzerland. Accessed October 1, 2020, at https://www.who.int/pehemf/about/WhatisEMF/en/index3.html. TN6561.

13
14
15

WNA (World Nuclear Association). 2017. “Thorium.” London, United Kingdom. Accessed
October 16, 2020, at https://www.world-nuclear.org/information-library/current-and-futuregeneration/thorium.aspx. TN6668.

16
17
18
19

WNA (World Nuclear Association). 2020. “Uranium Enrichment.” London, United Kingdom.
Webpage accessed October 16, 2020, at https://www.world-nuclear.org/informationlibrary/nuclear-fuel-cycle/conversion-enrichment-and-fabrication/uranium-enrichment.aspx.
TN6661.

20
21
22

WNA (World Nuclear Association). 2021. “Molten Salt Reactors.” London, United Kingdom.
Webpage accessed June 7, 2021, at https://www.world-nuclear.org/information-library/currentand-future-generation/molten-salt-reactors.aspx. TN7072.

23
24
25

WNA (World Nuclear Association). 2021. “Nuclear Fuel and its Fabrication.” London, United
Kingdom. Accessed July 2, 2024, at https://world-nuclear.org/information-library/nuclear-fuelcycle/conversion-enrichment-and-fabrication/fuel-fabrication. TN10153.

26
27
28

WNN (World Nuclear News). 2020. “X-energy TRISO-X Fuel to be Irradiated at MIT.” London,
United Kingdom. Webpage accessed November 9, 2020, at https://world-nuclearnews.org/Articles/X-energy-TRISO-X-fuel-to-be-irradiated-at-MIT. TN6740.

29
30
31
32

WSDOT (Washington State Department of Transportation). 2017. “Construction Noise Impact
Assessment.” Chapter 7 in Biological Assessment Preparation for Transportation Projects –
Advanced Training Manual. Olympia, Washington. Available at
http://www.wsdot.wa.gov/sites/default/files/2018/01/18/Env-FW-BA_ManualCH07.pdf. TN5313.

33
34

X-Energy (X-Energy, LLC). 2020. “TRISO-X.” Greenbelt, Maryland. Webpage accessed August
25, 2020, at https://x-energy.com/fuel/triso-x. TN6736.

35
36

Yahner, R.H. 2000. Eastern Deciduous Forest: Ecology and Wildlife Conservation. University of
Minnesota Press, Minneapolis, Minnesota. DOI: 10.5749/j.ctttsrbh. TN6565.

5-32

APPENDIX A

1
2
3

CONTRIBUTORS TO THE ENVIRONMENTAL IMPACT STATEMENT

4
5
6
7

Members of the U.S. Nuclear Regulatory Commission prepared this generic environmental
impact statement with assistance and support from Pacific Northwest National Laboratory and a
commercial contractor. The table below identifies each contributor’s name, affiliation, and
function or expertise.

Table A-1
Name
Jack Cushing(a)

Stacey Imboden

Laura Willingham
Dan Barnhurst
Jennifer Davis
Peyton Doub

Kevin Folk
Dan Mussatti(b)

Donald Palmrose

Jeffrey Rikhoff

U.S. Nuclear Regulatory Commission Preparers
Affiliation
Review Area/Expertise
Office of Nuclear Material Safety and Project Management, Historic and
Safeguards
Cultural Resources, Cumulative
Impacts
Office of Nuclear Material Safety and Project Management, Meteorology
Safeguards
and Air Quality, Climate Change,
Nonradiological Environment
Office of Nuclear Material Safety and Project Management, Meteorology
Safeguards
and Air Quality, Climate Change
Office of Nuclear Material Safety and Surface Water and Groundwater
Safeguards
Resources, Project Management
Office of Nuclear Material Safety and Historic and Cultural Resources
Safeguards
Office of Nuclear Material Safety and Land Use, Terrestrial Ecology,
Safeguards
Aquatic Ecology, Visual
Resources, Alternatives, Executive
Summary
Office of Nuclear Material Safety and Surface Water and Groundwater
Safeguards
Resources
Office of Nuclear Material Safety and Visual Resources, Noise,
Safeguards
Socioeconomics, Environmental
Justice, Need for Project
Office of Nuclear Material Safety and Radiological Environment,
Safeguards
Accidents, Radiological Waste
Management, Fuel Cycle,
Transportation of Fuel and Waste,
Decommissioning, Continued
Storage
Office of Nuclear Material Safety and Environmental Justice
Safeguards

(a) Retired from the U.S. Nuclear Regulatory Commission in 2021.
(b) Retired from the U.S. Nuclear Regulatory Commission in 2023.

A-1

Table A-2

Pacific Northwest National Laboratory(a) Preparers

Name
Bo Saulsbury(b)
Dave Goodman
Andrew Kugler
Terri Miley/Sadie Montgomery
Bruce McDowell/Saikat Ghosh
Rajiv Prasad/Kazi Tamaddun
Philip Meyer/Rebecka Bence
Stephanie Larson/Tracy Fuentes/Jim
Becker
Ann Miracle/Stephanie Larson
Tara O’Neil/Lindsey Renaud/Ellen
Kennedy
Dave Anderson
Kim Leigh/Seema Verma
Caitlin Condon/Jon Napier/Steve Maheras

Review Area/Expertise
Project Management
Project Management, Land Use, Visual Resources, Noise,
Alternatives Analysis, Cumulative Impacts
Project Management, Plant and Site Parameter Envelopes,
Alternatives
Comment Response
Air Quality
Surface Water Resources
Groundwater Resources
Terrestrial Ecology
Aquatic Ecology
Historic and Cultural Resources
Socioeconomics, Environmental Justice
Nonradiological Environment
Radiological Environment, Waste Management, Fuel Cycle,
Decommissioning, Accidents, Transportation of Fuel and
Waste, Continued Storage

(a) Pacific Northwest National Laboratory (PNNL) is managed for the U.S. Department of Energy by Battelle
Memorial Institute.
(b) Formerly of PNNL.

A-2

APPENDIX B

1
2
3
4
5
6
7
8
9

OUTREACH
This appendix provides a description of outreach activities and the Federal, State, and Tribal
agencies and groups that the U.S. Nuclear Regulatory Commission (NRC) contacted during the
preparation of this Generic Environmental Impact Statement for Licensing New Nuclear
Reactors (NR GEIS). The NRC did not identify any cooperating agencies for the environmental
review or receive any formal requests for cooperating agency status. The NRC staff conducted
extensive outreach during preparation of the draft NR GEIS and rule.

B.1

Exploratory Process

11
12
13
14
15
16
17

On November 15, 2019, the NRC staff issued the following Federal Register Notices (84 FR
62559-TN6470, 84 FR 67299-TN7085, and 84 FR 68194-TN7084) announcing an exploratory
process and soliciting comments to determine the possibility of developing a GEIS for licensing
advanced nuclear reactors. The exploratory process included two public meetings, a
comprehensive public workshop attended by multiple stakeholders, and a site visit to the Idaho
National Laboratory, a location that is being contemplated for advanced reactors (NRC 2019TN7087, NRC 2019-TN7086, NRC 2020-TN7088).

B.2

19
20
21

On May 28, 2020 from 1:00 p.m. to 4:00 p.m. the NRC staff held a webinar with the public as
part of the scoping process to gather information necessary to prepare a GEIS for advanced
nuclear reactors (85 FR 24040-TN6458).

B.3

23
24
25

The staff collected comments from the public three ways during the public comment period
associated with the initial scoping process, held from April 30, 2020 to June 30, 2020 (85 FR
24040-TN6458).

Public Meetings and Webinars

Obtaining Comments

26
27
28

• Federal Rulemaking website: The public submitted comments to the NRC staff through the
Federal Rulemaking website at https://www.regulations.gov using Docket ID NRC-20200101.

29
30
31

• Advanced Reactors-GEIS Email: The NRC staff used an email account,
AdvancedReactors-GEIS@nrc.gov, to receive comments from the public during the initial
scoping process for the GEIS.

32
33
34

• Mail: The NRC staff requested that comments be sent by mail, if desired, to Office of
Administration, Mail Stop TWFN-7-A60M, U.S. Nuclear Regulatory Commission,
Washington, D.C. 20555-0001.

B.4

Distribution of the Scoping Summary Report

36
37
38
39

The NRC staff summarized the comments received during the scoping process and the staff’s
related responses in a report titled, Environmental Impact Statement Scoping Process Summary
Report: The Advanced Nuclear Reactor Generic Environmental Impact Statement Public
Scoping Period (NRC 2020-TN6593). This scoping report was issued in September 2020.

B-1

B.5

NRC Website

2
3
4
5
6
7
8
9
10
11
12

Throughout the development of the NR GEIS and the rulemaking process, the NRC maintained
a webpage at: https://www.nrc.gov/reactors/new-reactors/advanced/details.html#advRxGEIS
(NRC 2021-TN7099). The NRC regularly updated the website, which contained a description of
the purpose of the GEIS and rulemaking, the history of the GEIS development and rulemaking,
and the schedule for the GEIS and rule. The website also provided an overview of key
communications between the staff and Commission (SECY-20-0020 [NRC 2020-TN6493] and
SRM-SECY-20-0020 [NRC 2’/020-TN6492]) and the public. In addition there is a website for the
rulemaking effort associated with the NR GEIS at https://www.nrc.gov/reading-rm/doccollections/rulemaking-ruleforum/active/ruledetails.html?id=1139 (NRC 2021-TN7103). This
website provides the public with rulemaking information such as the schedule, the NRC docket
ID, and the rulemaking project manager information along with other information.

B.6

14
15
16
17
18

On at least nine occasions, the NRC staff has taken part in the periodic Advanced Reactor
Stakeholder Meetings to provide an overview of the GEIS development and answer questions.
All meetings were open to the public and associated slides may be found at
https://www.nrc.gov/reactors/new-reactors/advanced/details.html#stakeholder (NRC 2021TN7099).

B.7

20
21
22
23
24
25
26

The NRC staff contacted federally recognized Tribes via a State and Tribal Correspondence
letter regarding scoping for the ANR GEIS (NRC 2020-TN7095). The staff distributed the
scoping summary report to Tribes via LYRIS distribution through the NRC Tribal liaison branch
(NRC 2020-TN7094, NRC 2020-TN7093, NRC 2020-TN7092, NRC 2020-TN7091, NRC 2020TN7090, NRC 2020-TN7089). Another State and Tribal Correspondence letter was sent to invite
Tribes to attend the July 15, 2021 Advanced Reactors Stakeholder meeting (NRC 2021TN7096).

B.8

28
29
30
31

On April 1, 2020, the NRC reached out to the Advisory Council on Historic Preservation and the
U.S. Environmental Protection Agency via email to notify them of the NRC’s intent to conduct a
scoping process for the ANR GEIS and to inform the agencies that the NRC would issue a
Federal Register Notice (NRC 2021-TN7097, NRC 2021-TN7098).

B.9

33
34
35

36
37
38

84 FR 67299. December 9, 2019. “Agency Action Regarding the Exploratory Process for the
Development of an Advanced Nuclear Reactor; Generic Environmental Impact Statement.”
Federal Register, Nuclear Regulatory Commission. TN7085.

Advanced Reactor Stakeholder Meetings

Tribal Contact

Other Federal Agencies

References

B-2

1
2
3

84 FR 68194. December 13, 2019. “Agency Action Regarding the Exploratory Process for the
Development of an Advanced Nuclear Reactor; Generic Environmental Impact Statement;
Correction.” Federal Register, Nuclear Regulatory Commission. TN7084.

4
5
6

85 FR 24040. April 30, 2020. “Notice To Conduct Scoping and Prepare an Advanced Nuclear
Reactor Generic Environmental Impact Statement.” Federal Register, Nuclear Regulatory
Commission. TN6458.

7
8
9
10
11

NRC (U.S. Nuclear Regulatory Commission). 2019. Memorandum from M.A. Sutton to B.G.
Beasley, Office of Nuclear Reactor Regulation, dated December 10, 2019, regarding “Summary
of November 15 and 20, 2019, Public Meetings to Discuss Exploratory Process for Developing
an Advanced Nuclear Reactor Generic Environmental Impact Statement.” Washington, D.C.
ADAMS Accession No. ML19337C862. TN7086.

12
13
14
15

NRC (U.S. Nuclear Regulatory Commission). 2019. Public Meeting Announcement and Agenda,
November 15 and 20, 2019, “Meeting to Discuss the Environmental Information Needed to
Develop a Generic Environmental Impact Statement for Advanced Nuclear Reactors.”
Washington, D.C. ADAMS Accession No. ML19304B011. TN7087.

16
17
18
19

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from J. Olmstead to NRC, dated
November 17, 2020, regarding “Scoping Summary Report for the Advanced Reactor Generic
Environmental Impact Statement.” Washington, D.C. ADAMS Accession No. ML21224A280.
TN7089.

20
21
22
23

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from L. Willingham to the Hopi Tribe,
dated November 17, 2020, regarding “U.S. Nuclear Regulatory Commission - Advanced
Reactor Generic Environmental Impact Statement Scoping Summary Report.” Washington, D.C.
ADAMS Accession No. ML21224A293. TN7091.

24
25
26
27

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from L. Willingham to the Miami Tribe
of Oklahoma, dated November 17, 2020, regarding “U.S. Nuclear Regulatory Commission Advanced Reactor Generic Environmental Impact Statement Scoping Summary Report.”
Washington, D.C. ADAMS Accession No. ML21224A296. TN7090.

28
29
30
31

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from L. Willingham to the Navajo
Nation, dated November 17, 2020, regarding “U.S. Nuclear Regulatory Commission - Advanced
Reactor Generic Environmental Impact Statement Scoping Summary Report.” Washington, D.C.
ADAMS Accession No. ML21224A292. TN7092.

32
33
34
35

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from L. Willingham to the San Manuel
Band of Mission Indians, dated November 17, 2020, regarding “U.S. Nuclear Regulatory
Commission - Advanced Reactor Generic Environmental Impact Statement Scoping Summary
Report.” Washington, D.C. ADAMS Accession No. ML21224A291. TN7093.

36
37
38
39

NRC (U.S. Nuclear Regulatory Commission). 2020. Email from L. Willingham to the ShoshoneBannock Tribe, dated November 17, 2020, regarding “U.S. Nuclear Regulatory Commission Advanced Reactor Generic Environmental Impact Statement Scoping Summary Report.”
Washington, D.C. ADAMS Accession No. ML21216A202. TN7094.

B-3

1
2
3
4
5

NRC (U.S. Nuclear Regulatory Commission). 2020. Letter from L.Y. Cuadrado to All Agreement
and Non-Agreement States, State Liaison Officers, and All Federally Recognized Indian Tribes,
dated April 30,2020, regarding “Notification of the Intent to Conduct a Scoping Process and
Prepare a Generic Environmental Impact Statement for Advanced Nuclear Reactors.”
Washington, D.C. ADAMS Accession No. ML20114E140. TN7095.

6
7
8
9
10

11
12
13
14

15
16
17
18

NRC (U.S. Nuclear Regulatory Commission). 2020. Public Meeting Announcement and Agenda,
January 08, 2020, “Workshop to Discuss the Environmental Information Needed to Develop a
Generic Environmental Impact Statement for Advanced Nuclear Reactors.” Washington, D.C.
ADAMS Accession No. ML19347A733. TN7088.

19
20
21

22
23

NRC (U.S. Nuclear Regulatory Commission). 2021. “Advanced Reactors Details.” Washington,
D.C. ADAMS Accession No. ML21232A543. TN7099.

24
25
26

NRC (U.S. Nuclear Regulatory Commission). 2021. Email from NRC to ACHP, dated April 1,
2021. regarding “NRC Preparing an Advance Nuclear Reactor Generic Environmental Impact
Statement (GEIS).” Washington, D.C. ADAMS Accession No. ML21219A001. TN7097.

27
28
29

NRC (U.S. Nuclear Regulatory Commission). 2021. Email from NRC to EPA, dated April 1,
2021. regarding “NRC Preparing an Advance Nuclear Reactor Generic Environmental Impact
Statement (GEIS).” Washington, D.C. ADAMS Accession No. ML21218A186. TN7098.

30
31
32
33
34

NRC (U.S. Nuclear Regulatory Commission). 2021. Letter from M. Arribas-Colon to All
Agreement States, Connecticut, Indiana, Non-Agreement States, State Liaison Officers, and
Federally Recognized Indian Tribes, dated July 12, 2021, regarding “Opportunity to Observe the
U.S. Nuclear Regulatory Commission Periodic Advanced Reactor Stakeholder Meeting (STC21-044).” Washington, D.C. ADAMS Accession No. ML21190A285. TN7096.

35
36

NRC (U.S. Nuclear Regulatory Commission). 2021. “Planned Rulemaking Activities - Rule.”
Washington, D.C. ADAMS Accession No. ML21232A497. TN7103.

B-4

APPENDIX C

1
2
3
4
5

CHRONOLOGY OF NRC STAFF ENVIRONMENTAL REVIEW
CORRESPONDENCE RELATED TO THE ADVANCED REACTOR
GENERIC ENVIRONMENTAL IMPACT STATEMENT

6
7
8

This appendix contains a chronological listing of correspondence between the U.S. Nuclear
Regulatory Commission (NRC) staff and external parties as part of its development of the
Generic Environmental Impact Statement for Licensing New Nuclear Reactors.

9
10
11
12
13
14
15

All documents, with the exception of those containing proprietary information, are available
electronically in the NRC’s Library, which is found on the Internet at the following Web address:
http://www.nrc.gov/reading-rm.html. From this site, the public can gain access to the NRC’s
Agencywide Documents Access and Management System (ADAMS), which provides text and
image files of the NRC’s public documents. The ADAMS accession number for each document
is included below. If you need assistance in accessing or searching in ADAMS, contact the
Public Document Room staff at 1-800-397-4209.

16
17
18

November 15, 2019

NRC Federal Register Notice (FRN) Announcing an Exploratory Process
and Soliciting Comments on a Possible ANR GEIS (84 FR 62559)
(Accession No. ML19302G126)

19
20
21

February 28, 2020

SECY-20-0020, Results of Exploratory Process for Developing a GEIS for
the Construction and Operation of Advanced Nuclear Reactors (Package
Accession No. ML20052D175)

22
23
24

April 1, 2020

Scoping e-mail to NRC, from J. Eddins, Advisory Council on Historic
Preservation, Regarding Preparation of a GEIS for Advanced Reactors
(Accession No. ML21219A001)

25
26
27

April 1, 2020

Scoping email to M. Roundtree, Environmental Protection Agency, from
NRC, Regarding Preparation of an Advance Nuclear Reactor GEIS
(Accession No. ML21218A186)

28
29

April 21, 2020

NRC FRN Announcing an Exploratory Process, Public Meetings, and
Soliciting Comments on an ANR GEIS (Accession No. ML20111A308)

30
31

April 30, 2020

NRC FRN Providing Notice of Intent to Conduct Scoping and Prepare an
ANR GEIS (85 FR 24040) (Accession No. ML20111A308)

32
33
34
35

April 30, 2020

NRC Notification to All Agreement and Non-Agreement States, State
Liaison Officers, and All Federally Recognized Indian Tribes, Regarding
Notice of Intent to Conduct Scoping and Prepare an ANR GEIS (STC-20036) (Accession No. ML20114E140)

36
37

April 30, 2020

Public Meeting Notice to Discuss the Scope of the GEIS for ANRs
(Accession No. ML20148M245)

C-1

1
2
3

May 14, 2020

E-mail to NRC, from K. Jensen, The Yocha Dehe Wintun Nation,
Regarding the Generic EIS for Small Scale ANR (Accession No.
ML21220A000)

4
5
6

May 14, 2020

E-mail to L. Bill, The Yocha Dehe Wintun Nation, from NRC, Regarding
Yocha Dehe Wintun Nation Notification Response (Accession No.
ML21220A001)

7
8

May 27, 2020

E-mail to M. Bremer, The Pueblo de San Ildefonso Tribe, from NRC,
Regarding the Generic EIS for ANR (Accession No. ML21220A003)

9
10

June 3, 2020

E-mail from A. McCleary, The San Manuel Band of Mission Indians,
Regarding attending the scoping meeting (Accession No. ML21223A341)

11
12
13
14

June 10, 2020

Letter to D. True, Nuclear Energy Institute, from NRC, Regarding the
Nuclear Energy Institute’s March 5, 2020 letter “Recommendations for
Streamlining Environmental Reviews for Advanced Reactors” (Accession
No. ML20147A540)

15
16

July 2, 2020

NRC Memorandum: Scoping Meeting Summary (Package Accession No.
ML20161A339)

17
18

July 23, 2020

Letter to NRC, from Senators J. Barrasso, M. Braun, and M. Crapo,
Regarding the ANR GEIS (Accession No. ML20206K923)

19
20
21

August 19, 2020

E-mail to D. Hunter, The Miami Tribe of Oklahoma, from NRC, Regarding
Notification of Intent to Review and update the Generic EIS (Accession
No. ML20233A558)

22
23

August 27, 2020

Letter to Senator J. Barrasso, from NRC, Regarding the Senator’s July
23, 202p letter on the ANR GEIS (Accession No. ML20225A074)

24
25
26

September 21, 2020 Staff Requirements Memorandum (SRM) 20-0020, Results of Exploratory
Process for Developing a GEIS for the Construction and Operation of
ANRs (Accession No. ML20265A112)

27
28
29

September 22, 2020 E-mail to Mr. Koyiyumptewa, The Hopi Tribe, from NRC, Regarding the
Hopi Tribe Response to the NRC’s April 30, 2020 letter (Accession No.
ML21223A408)

30
31

September 25, 2020 ANR GEIS Scoping Summary Report (Package Accession No.
ML20260H180)

32
33

November 17, 2020

Email to T. Martin, The Shoshone Bannock Tribe, from NRC, Regarding
the ANR GEIS Scoping Summary Report (Accession No. ML21216A202)

34
35
36

November 17, 2020

E-mail to A. McCleary, The San Manuel Band of Mission Indians,
transmitting the ANR GEIS Scoping Summary Report (Accession No.
ML21224A291)

C-2

1
2

November 17, 2020

E-mail to Mr. Karr, Navajo Nation, Department of Justice, transmitting the
ANR GEIS Scoping Summary Report (Accession No. ML21224A292)

3
4

November 17, 2020

E-mail to Mr. Koyiyumptewa, The Hopi Tribe, transmitting the ANR GEIS
Scoping Summary Report (Accession No. ML21224A293)

5
6

November 17, 2020

Email to D. Hunter, The Miami Tribe of Oklahoma, transmitting the ANR
GEIS Scoping Summary Report (Accession No. ML21224A296)

7
8

November 17, 2020

Email from Joan Olmstead transmitting the Scoping summary report to
Tribal and State Liaison Contacts (Accession No. ML21224A280)

9
10

December 14, 2021

Submittal of Proposed Rule: Advanced Nuclear Reactor Generic
Environmental Impact Statement (Accession No. ML21222A044)

11
12
13

April 18, 2024

Staff Requirements Memorandum – SECY-21-0098 – Proposed Rule:
Advanced Nuclear Reactor Generic Environmental Impact Statement
(Accession No. ML24108A200)

C-3

APPENDIX D

1
2
3

DISTRIBUTION LIST

4
5
6
7
8
9
10

The U.S. Nuclear Regulatory Commission (NRC) is providing copies of the Generic
Environmental Impact Statement for Licensing New Nuclear Reactors (NR GEIS) to the
organizations and individuals listed below. In addition, the NRC will issue a State and Tribal
Correspondence letter to notify all federally recognized Tribes and State liaison contacts. The
NRC will also send the NR GEIS to over 3,000 private citizens that provided scoping comments
during the scoping period held for the GEIS from April to June 2020. The NRC will provide hard
copies to other interested organizations and individuals upon request.

Table D-1
Name
John Eddins
William James
Robert Tomiak
Bud Albright
Peter Hastings
Edwin Lyman
Nicholas McMurray
Marcus Nichol
Caleb Ward

Distribution List

Affiliation
Federal Agencies
Advisory Council on Historic Preservation
U.S. Army Corps of Engineers
U.S. Environmental Protection Agency (EPA) Office of Federal Activities
Other Organizations and Individuals
U.S. Nuclear Industry Council
Kairos
Union of Concerned Scientists
ClearPath
Nuclear Energy Institute
U.S. Nuclear Industry Council

D-1

APPENDIX E

1
2
3
4

COMMENTS ON THE GEIS
E.1

Public Scoping

5
6
7
8
9
10

On April 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) issued, for public comment,
a notice of intent to prepare an advanced nuclear reactor (ANR) generic environmental impact
statement (GEIS) and to conduct a scoping process to gather the information necessary to
prepare such a GEIS for small-scale ANRs (85 FR 24040-TN6458). The NRC held a webinar on
May 28, 2020, to receive comments from the public on the scope of the GEIS (NRC 2020TN6459).

11
12
13
14
15
16

The NRC received a number of comments about the scope of this GEIS both during the May 28,
2020 webinar and throughout the scoping comment period. The NRC staff and its contractor
reviewed the transcript from the webinar and all written materials received during the public
comment period. All comments were considered. The NRC staff issued a summary of the
scoping comments, and the staff’s responses to those comments, on September 25, 2020
(NRC 2020-TN6593).

17
18
19
20
21
22

In accordance with 10 CFR 51.29(b) (TN250), this scoping summary report has been made
publicly available at the NRC Public Document Room, located at One White Flint North,
11555 Rockville Pike, Rockville, Maryland 20852, or from the Agencywide Documents Access
and Management System (ADAMS). The ADAMS Public Electronic Reading Room is
accessible through the NRC’s public website, www.nrc.gov. The accession number for the
scoping summary report is ML20269A317.

E.2

(Reserved for future use.)

E.3

26
27

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental
Protection Regulations for Domestic Licensing and Related Regulatory Functions.” TN250.

28
29
30

85 FR 24040. April 30, 2020. “Notice To Conduct Scoping and Prepare an Advanced Nuclear
Reactor Generic Environmental Impact Statement.” Federal Register, Nuclear Regulatory
Commission. TN6458.

31
32
33

34
35
36

Comments on the Draft GEIS

References

E-1

APPENDIX F

1
2
3
4
5
6
7
8
9
10
11

LAWS, REGULATIONS, AND OTHER AUTHORIZATIONS
F.1

Introduction

This appendix presents a brief discussion of Federal and State laws, regulations, and other
requirements that may affect the application for and issuance of a license for a new nuclear
reactor. The Federal and State laws, regulations, and other requirements listed herein are
designed to protect the environment and address the following topics: land and water use, air
quality, aquatic resources, terrestrial resources, radiological impacts, waste management,
chemical impacts, and socioeconomic conditions. Title 10 of the Code of Federal Regulations
(10 CFR) 51.45(d) (TN250), “Status of compliance,” states:

12
13
14
15
16
17
18
19
20
21
22

The environmental report shall list all Federal permits, licenses, approvals, and
other entitlements which must be obtained in connection with the proposed
action and shall describe the status of compliance with these requirements. The
environmental report shall also include a discussion of the status of compliance
with applicable environmental quality standards and requirements including, but
not limited to, applicable zoning and land-use regulations, and thermal and other
water pollution limitations or requirements which have been imposed by Federal,
State, regional, and local agencies having responsibility for environmental
protection. The discussion of alternatives in the report shall include a discussion
of whether the alternatives will comply with such applicable environmental quality
standards and requirements.

23
24
25

The U.S. Nuclear Regulatory Commission (NRC) uses compliance with other laws and
regulations designed to protect the environment in the assessment of environmental impacts in
its environmental impact statement (EIS).

26
27
28
29
30
31
32

This appendix is intended to provide a basic overview to assist the applicant in identifying
environmental and natural resources laws that may affect the new nuclear reactor licensing
process. The descriptions of the laws, regulations, Executive Orders, and other directives are
general in nature and are not intended to provide a comprehensive analysis or explanation of
any of the items listed. In addition, the list itself is not intended to be comprehensive, and an
applicant for a new nuclear reactor license is reminded that a variety of additional Federal,
State, or local requirements may apply to their application.

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Section F.2 identifies Federal laws and regulations that may be applicable to the new nuclear
reactor licensing process. Section F.3 discusses relevant environmental Executive Orders, and
Section F.4 identifies applicable NRC regulations. Section F.5 discusses State laws,
regulations, and agreements, and Section F.6 discusses emergency management and
response laws, regulations, and Executive Orders. Section F.7 discusses laws that contain
requirements for consultation with agencies and federally recognized American Indian Nations.

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The Federal laws and regulations that are identified and briefly discussed in this section are
presented in alphabetical order.

Federal Laws and Regulations

F-1

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2
3

American Indian Religious Freedom Act of 1978 (42 United States Code [U.S.C.] § 1996;
TN5281) – The American Indian Religious Freedom Act protects Native Americans’ rights of
freedom to believe, express, and exercise traditional religions.

4
5
6
7

Antiquities Act of 1906, as amended (54 U.S.C. §§ 320301–320303 and 18 U.S.C.
§ 1866(b); TN6602) – The Antiquities Act protects historic and prehistoric ruins, monuments,
and antiquities, including paleontological resources, on federally controlled lands from
appropriation, excavation, injury, and destruction without permission.

8
9
10
11
12

Archeological and Historic Preservation Act of 1974, as amended (54 U.S.C. §§ 312501
et seq.; TN4844) – The Archeological and Historic Preservation Act establishes procedures for
preserving historical and archaeological resources. Analysis of environmental compliance
included assessing the energy alternatives for possible impacts on prehistoric, historic, and
traditional cultural resources.

13
14
15
16
17
18
19
20

Archaeological Resources Protection Act of 1979, as amended (54 U.S.C. §§ 302101
et seq.; TN1687) – The Archaeological Resources Protection Act requires a permit for any
excavation or removal of archaeological resources from Federal or American Indian lands.
Excavations must be undertaken for the purpose of furthering archaeological knowledge in the
public interest, and resources removed are to remain the property of the United States. Consent
must be obtained from the American Indian Tribe or the Federal agency that has authority over
the land, on which a resource is located, before issuance of a permit. The permit must contain
terms and conditions requested by the Tribe or Federal agency.

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23
24
25
26
27

Atomic Energy Act of 1954 (42 U.S.C. §§ 2011 et seq.; TN663) – The 1954 Atomic Energy
Act (AEA), as amended, and the Energy Reorganization Act of 1974 (42 U.S.C. § 5801 et seq.;
TN4466) gives the NRC the licensing and regulatory authority for nuclear energy uses within the
commercial sector. It gives the NRC responsibility for licensing and regulating commercial uses
of atomic energy and allows the NRC to establish dose and concentration limits for protection of
workers and the public for activities under NRC jurisdiction. The NRC implements its
responsibilities under the AEA through regulations set forth in 10 CFR.

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30
31
32
33
34

Bald and Golden Eagle Protection Act of 1940, as amended (16 U.S.C. §§ 668–668d;
TN1447) – The Bald and Golden Eagle Protection Act makes it unlawful to take, pursue, molest,
or disturb bald and golden eagles, their nests, or their eggs anywhere in the United States. The
U.S. Fish and Wildlife Service (FWS) may issue take permits to individuals, government
agencies, or other organizations to authorize limited, non-purposeful disturbance of eagles, in
the course of conducting lawful activities such as operating utilities or conducting scientific
research.

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37
38
39
40
41
42
43
44
45

Clean Air Act of 1970, as amended (42 U.S.C. §§ 7401 et seq.; TN1141) – The Clean Air Act
(CAA) is intended to “protect and enhance the quality of the nation’s air resources so as to
promote the public health and welfare and the productive capacity of its population.” The CAA
establishes regulations to ensure maintenance of air quality standards and authorizes individual
States to manage permits. Section 118 of the CAA requires each Federal agency, with
jurisdiction over properties or facilities engaged in any activity that might result in the discharge
of air pollutants, to comply with all Federal, State, interstate, and local requirements with regard
to the control and abatement of air pollution. Section 109 of the CAA directs the U.S.
Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards
(NAAQSs) for criteria pollutants. The EPA has identified and set NAAQSs for the following
criteria pollutants: particulate matter, sulfur dioxide, carbon monoxide, ozone, nitrogen dioxide,

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and lead. Section 111 of the CAA requires establishment of national performance standards for
new or modified stationary sources of atmospheric pollutants. Section 160 of the CAA requires
that specific emission increases must be evaluated prior to permit approval in order to prevent
significant deterioration of air quality. Section 112 requires specific standards for release of
hazardous air pollutants (including radionuclides). These standards are implemented through
plans developed by each State and approved by the EPA. The CAA requires sources to meet
standards and obtain permits to satisfy those standards. Nuclear power plants may be required
to comply with the CAA Title V, Sections 501–507, for sources subject to new source
performance standards or sources subject to National Emission Standards for Hazardous Air
Pollutants. Emissions of air pollutants are regulated by the EPA in 40 CFR Parts 50 to 99
(TN5264).

12
13
14
15
16
17

Clean Water Act (33 U.S.C. §§ 1251 et seq.; TN662) – The Clean Water Act (CWA; formerly
the Federal Water Pollution Control Act of 1972) was enacted to “restore and maintain the
chemical, physical, and biological integrity of the Nation’s water.” The Act requires all branches
of the Federal government, with jurisdiction over properties or facilities engaged in any activity
that might result in a discharge or runoff of pollutants to surface waters, to comply with Federal,
State, interstate, and local requirements.

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33
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35

As authorized by the CWA, the National Pollutant Discharge Elimination System (NPDES)
permit program controls water pollution by regulating point sources that discharge pollutants into
waters of the United States. The NPDES program requires that all facilities that discharge
pollutants from any point source into waters of the United States obtain an NPDES permit. An
NPDES permit is developed with two levels of controls: technology-based limits and water
quality-based limits. NPDES permit terms may not exceed 5 years, and the applicant must
reapply at least 180 days prior to the permit expiration date. A nuclear power plant may also
participate in the NPDES General Permit for Industrial Stormwater due to stormwater runoff
from industrial or commercial facilities to waters of the United States. The EPA is authorized
under the CWA to directly implement the NPDES program; however, the EPA has authorized
many States to implement all or parts of the national program. Section 401 of the CWA requires
that an applicant for a Federal license or permit, whose activities may cause a discharge of
regulated pollutants into navigable waters, provide the Federal licensing or permitting agency
with a certification from the State or appropriate water pollution control agency in which the
discharge originates or will originate. This water quality certification implies that discharges from
the activity or project to be licensed or permitted will comply with CWA requirements, as
applicable, including that the discharge will not cause or contribute to a violation of applicable
water quality standards.

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42
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44
45
46

The U.S. Army Corps of Engineers (USACE) is the lead agency for enforcement of CWA
wetland requirements (33 CFR Part 320-TN424). Under Section 401 of the CWA, the EPA or a
delegated State agency has the authority to review and approve, condition, or deny all permits
or licenses that might result in a discharge to waters of the State, including wetlands. CWA
Section 401 [33 U.S.C. 1341(a)(1)] states: “No license or permit shall be granted until the
certification required by this section has been obtained or has been waived as provided in the
preceding sentence. No license or permit shall be granted if certification has been denied by the
State, inter-State agency, or the Administrator, as the case may be.” Therefore, the NRC cannot
issue its license without a 401 certification or an NRC determination that a waiver has occurred,
in accordance with 40 CFR 121.9(c) (TN6718). In accordance with 10 CFR 50.54(aa) (TN249),
conditions in the 401 Certification become a condition of the NRC’s license.

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A Section 404 permit would need to be obtained from the USACE before implementing any
action, such as earthmoving activities and certain erosion controls, which could disturb
wetlands. Federal and State permits/certifications are obtained using the same form and permit
applications for activities affecting waterways, and wetlands are reviewed by the USACE in
consultation with the FWS, the Soil Conservation Service, the EPA, and the delegated State
agency.

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16
17

Coastal Zone Management Act of 1972, as amended (16 U.S.C. §§ 1451 et seq.; TN1243) –
Congress enacted the Coastal Zone Management Act in 1972 to address the increasing
pressures of over-development upon the nation’s coastal resources. The National Oceanic and
Atmospheric Administration administers the Act. The Coastal Zone Management Act
encourages States to preserve, protect, develop, and, where possible, restore or enhance
valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, dunes,
barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. Participation
by States is voluntary. To encourage States to participate, the Coastal Zone Management Act
makes Federal financial assistance available to any coastal State or territory, including those on
the Great Lakes, that are willing to develop and implement a comprehensive coastal
management program.

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Comprehensive Environmental Response, Compensation, and Liability Act as amended
by the Superfund Amendments and Reauthorization Act (42 U.S.C. §§ 9601 et seq.;
TN6592) – The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) includes an emergency response program to respond to a release of a hazardous
substance to the environment. Releases of source, byproduct, or special nuclear material from a
nuclear incident are excluded from CERCLA requirements if the releases are subject to the
financial protection requirements of the AEA. CERCLA is intended to provide a response to, and
cleanup of, environmental problems that are not covered adequately by the permit programs of
the many other environmental laws, including the CAA; CWA; Safe Drinking Water Act (SDWA);
Marine Protection, Research, and Sanctuaries Act (33 U.S.C. §§ 1401 et seq.; TN6637);
Resource Conservation and Recovery Act (RCRA); and AEA. Under Section 120 of CERCLA,
each department, agency, and instrumentality (e.g., a municipality) of the United States is
subject to, and must comply with, CERCLA in the same manner as any nongovernmental entity
(except for requirements for bonding, insurance, financial responsibility, or applicable time
period). Under CERCLA, the EPA would have the authority to regulate hazardous substances at
a facility in the event of a release or a “substantial threat of a release” of those materials.
Releases greater than reportable quantities would be reported to the National Response Center.
Assessment of alternatives for environmental compliance includes consideration of whether
hazardous substances, in reportable quantity amounts, could be present at power plants during
the license term.

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41
42
43
44
45
46
47
48

Emergency Planning and Community Right-to-Know Act of 1986 (42 U.S.C. §§ 11001
et seq.; TN6603) (also known as “SARA Title III”) – The Emergency Planning and
Community Right-to-Know Act of 1986 (EPCRA), which is the major amendment to CERCLA
(42 U.S.C. § 9601; TN6592), establishes the requirements for Federal, State, and local
governments, American Indian Tribes, and industry regarding emergency planning and
“Community Right-to-Know” reporting on hazardous and toxic chemicals. The “Community
Right-to-Know” provisions increase the public’s knowledge and access to information about
chemicals at individual facilities, their uses, and releases into the environment. States and
communities working with facilities can use the information to improve chemical safety and
protect public health and the environment. This Act requires emergency planning and notice
to communities and government agencies concerning the presence and release of

F-4

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2

specific chemicals. The EPA implements this Act under regulations found in 40 CFR
Part 355 (TN5493), Part 370 (TN6612), and Part 372 (TN6613).

3
4
5
6
7

Endangered Species Act of 1973 (16 U.S.C. § 1531–1544; TN1010) – The Endangered
Species Act (ESA) was enacted to prevent the further decline of endangered and threatened
species and to restore those species and their critical habitats. Section 7 of the Act requires
Federal agencies to consult with the FWS or the National Marine Fisheries Service (NMFS) for
Federal actions that may affect listed species or designated critical habitats.

8
9
10
11
12
13

Environmental Standards for Uranium Fuel Cycle (40 CFR Part 190, Subpart B; TN739) –
These regulations establish maximum doses to the body or organs of members of the public as
a result of normal operational releases from uranium fuel cycle activities, including uranium
enrichment. These regulations were promulgated by the EPA under the authority of the AEA, as
amended, and have been incorporated by reference in the NRC regulations in 10 CFR
20.1301(e) (TN283).

14
15
16
17
18
19

Federal Insecticide, Fungicide, and Rodenticide Act, as amended (7 U.S.C. §§ 136 et seq.;
TN4535) – The Federal Insecticide, Fungicide, and Rodenticide Act, as amended, by the
Federal Environmental Pesticide Control Act and subsequent amendments, requires the
registration of all new pesticides with the EPA before they are used in the United States.
Manufacturers are required to develop toxicity data for their pesticide products. Toxicity data
may be used to determine permissible discharge concentrations for an NPDES permit.

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22
23
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25
26
27
28
29
30

Fiscal Responsibility Act of 2023 (Public Law 118-5) – The Fiscal Responsibility Act enacted
amendments to the National Environmental Policy Act (NEPA), aimed at streamlining the
decision-making process and codifying existing structures for cooperation between Federal
agencies. The Act established page and time limits for the environmental review process.
Environmental assessments are limited to 75 pages, not including citations or appendices, while
EISs are limited to 150 pages, with a 300-page limit for EISs that address an agency action of
“extraordinary complexity,” not including citations or appendices. The environmental
assessment are required to take no more than 1 year to complete, while EISs are limited to
2 years. The Act also allows for common categorical exclusions to be used between agencies
and codifies agency use of programmatic environmental documents to facilitate the NEPA
review process.

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32
33
34
35
36
37

Fish and Wildlife Conservation Act of 1980 (16 U.S.C. §§ 2901 et seq.; TN6604) – The Fish
and Wildlife Conservation Act provides Federal technical and financial assistance to States for
the development of conservation plans and programs for nongame fish and wildlife. Fish and
Wildlife Conservation Act conservation plans identify significant problems that may adversely
affect nongame fish and wildlife species and their habitats and appropriate conservation actions
to protect the identified species. The Act also encourages Federal agencies to conserve and
promote the conservation of nongame fish and wildlife and their habitats.

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39
40
41
42
43
44

Fish and Wildlife Coordination Act of 1934, as amended (16 U.S.C. §§ 661–666e; TN4467)
– The Fish and Wildlife Coordination Act requires Federal agencies that construct, license, or
permit water resource development projects to consult with the FWS (or NMFS, when
applicable) and State wildlife resource agencies for any project that involves an impoundment of
more than 10 ac (4 ha), diversion, channel deepening, or other waterbody modification
regarding the impacts of that action to fish and wildlife and any mitigative measures to reduce
adverse impacts.

F-5

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12

Fixing America’s Surface Transportation Act (42 U.S.C. §§ 4370m et seq.; TN6392) –
Title 41 of the Fixing America’s Surface Transportation Act (FAST-41) established new
coordination and oversight procedures for infrastructure projects being reviewed by Federal
agencies. FAST-41 is intended to accomplish the following:
• Increase predictability
–
–

through the publication of project-specific permitting timetables and
clear processes to modify permitting timetables and resolve issues.

• Increase transparency and accountability over the
–
–

Federal environmental review and
authorization process.

• Improve early coordination of agencies’ schedules and synchronization of environmental
reviews and authorizations.

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14

FAST-41 established the Federal Permitting Improvement Steering Council, which is composed
of agency representatives from various Federal agencies.

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21
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23

To be eligible for FAST-41, a proposal must meet the definition of a “covered project” under the
statute. A covered project is one that: (1) is subject to the NEPA; (2) is likely to require a total
investment of more than $200,000,000; and (3) does not qualify for abbreviated authorization or
environmental review processes under any applicable law. A covered project can also be one
that is subject to NEPA and is of the size and complexity which, in the opinion of Federal
Permitting Improvement Steering Council, make the project likely to benefit from enhanced
oversight and coordination, including a project likely to require (1) authorization from or
environmental review involving more than two Federal agencies; or (2) the preparation of an EIS
under NEPA.”

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28
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30

Hazardous Materials Transportation Act, as amended (49 U.S.C. §§ 5101 et seq.; TN6605)
– The Hazardous Materials Transportation Act regulates the transportation of hazardous
material (including radioactive material) in and between States. According to the Act, States
may regulate the transport of hazardous material as long as their regulation is consistent with
the Act or the U.S. Department of Transportation regulations provided in 49 CFR Parts 171
through 177 (TN5466). Other regulations regarding packaging for transportation of radionuclides
are contained in 49 CFR Part 173, Subpart I (TN298).

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33
34
35
36
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38
39

Low-Level Radioactive Waste Policy Act of 1980, as amended (42 U.S.C. §§ 2021b et seq.;
TN6606) – The Low-Level Radioactive Waste Policy Act amended the AEA to improve the
procedures for the implementation of compacts providing for the establishment and operation of
regional low-level radioactive waste disposal facilities. It also allows for Congress to grant
consent for certain inter-State compacts. The amended Act sets forth the responsibilities for
disposal of low-level waste by States or inter-State compacts. The Act states the amount of
waste that certain low-level waste recipients can receive over a set time period. The amount of
low-level radioactive waste generated from both pressurized and boiling water reactor types is
allocated over a transition period until a local waste facility is operational.

F-6

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2
3
4
5
6
7

Magnuson-Stevens Fishery Conservation and Management Act, as amended
(16 U.S.C. §§ 1801–1884; TN1061) – The Magnuson-Stevens Fishery Conservation and
Management Act governs marine fisheries management in U.S. Federal waters. The Act
created eight regional fishery management councils and includes measures to rebuild
overfished fisheries, protect essential fish habitat, and reduce bycatch. Under Section 305 of the
Act, Federal agencies are required to consult with NMFS for any Federal actions that may
adversely affect essential fish habitat.

8
9
10
11
12
13
14
15

Marine Mammal Protection Act of 1972 (16 U.S.C. §§ 1361 et seq.; TN4478) – The Marine
Mammal Protection Act (MMPA) was enacted to protect and manage marine mammals and
their products (e.g., the use of hides and meat). The primary authority for implementing the Act
belongs to the FWS and NMFS. The FWS manages walruses, polar bears, sea otters, dugongs,
marine otters, and the West Indian, Amazonian, and West African manatees. The NMFS
manages whales, porpoises, seals, and sea lions. The two agencies may issue permits under
MMPA Section 104 (16 U.S.C. § 1374) to persons, including Federal agencies, that authorize
the taking or importing of specific species of marine mammals.

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After the Secretary of the Interior or the Secretary of Commerce approves a State’s program,
the State can take over responsibility for managing one or more marine mammals. The MMPA
also established a Marine Mammal Commission whose duties include reviewing laws and
international conventions related to marine mammals, studying the condition of these mammals,
and recommending steps to Federal officials (e.g., listing a species as endangered) that should
be taken to protect marine mammals. Federal agencies are directed by MMPA Section 205
(16 U.S.C. § 1405) to cooperate with the Commission by permitting it to use their facilities or
services.

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28

Migratory Bird Treaty Act of 1918, as amended (16 U.S.C. §§ 703 et seq.; TN3331) – The
Migratory Bird Treaty Act is intended to protect birds that have common migration patterns
between the United States and Canada, Mexico, Japan, and Russia. The Act stipulates that,
except as permitted by regulations, it is unlawful at any time, by any means, or in any manner to
pursue, hunt, take, capture, or kill any migratory bird.

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35
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39
40
41
42

National Environmental Policy Act of 1969, as amended (42 U.S.C. § 4321 et seq.) – NEPA
requires, in part, that Federal agencies integrate environmental values into their decisionmaking process by considering the reasonably foreseeable environmental effects (impacts) of
proposed Federal actions and a reasonable range of alternatives to those actions. NEPA
establishes policy, sets goals (in Section 101), and provides means (in Section 102) for carrying
out the policy. Section 102(2) contains action-forcing provisions to ensure that Federal agencies
follow the letter and spirit of the Act. For major Federal actions significantly affecting the quality
of the human environment, Section 102(2)(C) of NEPA, consistent with the provisions of NEPA
except where compliance would be inconsistent with other statutory requirements, requires
Federal agencies to prepare a detailed statement that includes the reasonably foreseeable
environmental effects of the proposed action and other specified information. This generic
environmental impact statement (GEIS) has been prepared in accordance with NEPA
requirements and NRC regulations (10 CFR Part 51) for implementing NEPA to ensure
compliance with Section 102(2).

43
44
45
46

National Historic Preservation Act of 1966, as amended (54 U.S.C. §§ 300101 et seq.;
TN4157) – The National Historic Preservation Act (NHPA) was enacted to create a national
historic preservation program, including the National Register of Historic Places and the
Advisory Council on Historic Preservation. Section 106 of the Act requires Federal agencies

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3
4
5

to take into account the effects of their undertakings on historic properties. The Advisory Council
on Historic Preservation regulations implementing Section 106 of the Act are found in
36 CFR Part 800 (TN513). The regulations call for public involvement in the Section 106
consultation process, including American Indian Tribes and other interested members of the
public, as applicable.

6
7
8
9
10
11

Native American Graves Protection and Repatriation Act of 1990 (25 U.S.C. § 3001;
TN1686) – The Native American Graves Protection and Repatriation Act establishes provisions
for the treatment of inadvertent discoveries of American Indian remains and cultural objects.
When discoveries are made during ground-disturbing activities, the activity in the area must
immediately stop, and reasonable protective efforts, proper notifications, and appropriate
disposition of the discovered items must be pursued.

12
13
14
15
16
17

Noise Control Act of 1972 (42 U.S.C. §§ 4901 et seq.; TN4294) – The Noise Control Act
delegates the responsibility of noise control to State and local governments. Commercial
facilities are required to comply with Federal, State, interstate, and local requirements regarding
noise control. Section 4 of the Noise Control Act directs Federal agencies to carry out programs
in their jurisdictions “to the fullest extent within their authority” and in a manner that furthers a
national policy of promoting an environment free from noise that jeopardizes health and welfare.

18
19
20
21
22
23
24
25

Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA, Public Law 115-439;
TN6469) – NEIMA’s purpose is to establish transparency and accountability measures on the
NRC’s budget and fee recovery programs as well as to require the Commission to develop the
regulatory framework necessary to enable the licensing of ANRs. The Act enables the licensing
of ANRs by, among other things, requiring the Commission to develop and implement riskinformed, performance-based licensing policies and guidance. The Act also defines the term
“advanced nuclear reactor.” The Act authorizes appropriations sums necessary for the
Commission to carry out the requirements of Section 103 of NEIMA.

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33
34
35
36

Nuclear Regulatory Commission License Termination Rule (10 CFR Part 20, Subpart E;
TN283) – The AEA assigns NRC the responsibility for licensing and regulating commercial uses
of atomic energy. When a licensed facility has completed its mission, the facility must meet
standards for cleanup in order to terminate its license. The License Termination Rule
establishes that the NRC will consider a site acceptable for unrestricted use if (1) the residual
radioactivity that is distinguishable from background radiation results in a total effective dose
equivalent to an average member of the critical group that does not exceed 25 mrem per year,
including that from groundwater sources of drinking water, and (2) the residual radioactivity has
been reduced to levels that are as low as reasonably achievable. The critical group is the group
of individuals reasonably expected to receive the greatest exposure to residual radioactivity for
any applicable set of circumstances.

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41
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43

The License Termination Rule also provides for land-use restrictions or other types of
institutional controls to allow for the termination of NRC licenses and the release of sites under
restricted conditions if decommissioning criteria for unrestricted use cannot be met. Plus, the
License Termination Rule establishes alternate criteria for license termination if the licensee
provides assurance that public health and safety would continue to be protected, and that it is
unlikely that the dose from all manufactured sources combined, other than medical, would be
more than 100 mrem per year.

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45

Nuclear Waste Policy Act of 1982 (42 U.S.C. §§ 10101 et seq.; TN740) – The Nuclear Waste
Policy Act provides for the research and development of repositories for the disposal of

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6

high-level radioactive waste, spent nuclear fuel, and low-level radioactive waste. Title I includes
the provisions for the disposal and storage of high-level radioactive waste and spent nuclear
fuel. Subtitle A of Title I delineates the requirements for site characterization and construction of
the repository and the participation of States and other local governments in the selection
process. Subtitles B, C, and D of Title I deal with the specific issues for interim storage,
monitored retrievable storage, and low-level radioactive waste.

7
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10
11
12
13

Occupational Safety and Health Act of 1970 (29 U.S.C. §§ 651 et seq.; TN4453) – The
Occupational Safety and Health Act establishes standards to enhance safe and healthy working
conditions in places of employment throughout the United States. The Act is administered and
enforced by the Occupational Safety and Health Administration (OSHA), a U.S. Department of
Labor agency. Employers who fail to comply with OSHA standards can be penalized by the
Federal government. The Act allows States to develop and enforce OSHA standards if such
programs have been approved by the Secretary of Labor.

14
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17

Pollution Prevention Act of 1990 (42 U.S.C. §§ 13101 et seq.; TN6607) – The Pollution
Prevention Act establishes a national policy for waste management and pollution control that
focuses first on source reduction, then on environmental issues, safe recycling, treatment, and
disposal.

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27

Resource Conservation and Recovery Act as amended by the Hazardous and Solid
Waste Amendments (42 U.S.C. §§ 6901 et seq.; TN1281) – The RCRA requires the EPA to
define and identify hazardous waste; establish standards for its transportation, treatment,
storage, and disposal; and require permits for persons engaged in hazardous waste activities.
Section 3006 (42 U.S.C. § 6926) allows States to establish and administer these permit
programs with EPA approval. EPA regulations implementing the RCRA are found in 40 CFR
Parts 239 through 283 (TN6618). Regulations imposed on a generator or on a treatment,
storage, and/or disposal facility vary according to the type and quantity of material or waste
generated, treated, stored, and/or disposed. The method of treatment, storage, and/or disposal
also affects the extent and complexity of the requirements.

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32
33
34
35
36
37
38
39

Rivers and Harbors Act of 1899, Section 10 (33 U.S.C. § 403) – The Rivers and Harbors Act
of 1899 (33 U.S.C. §§ 401 et seq.) requires USACE authorization in order to protect navigable
waters in the development of harbors and other construction and excavation. Section 10 of the
Rivers and Harbors Act of 1899 (33 U.S.C. § 403) prohibits the unauthorized obstruction or
alteration of any navigable water of the United States. That section provides that the
construction of any structure in or over any navigable water of the United States, or the
accomplishment of any other work affecting the course, location, condition, or physical capacity
of such waters is unlawful unless the work has been authorized by the Secretary of the Army
through the USACE. Activities requiring Section 10 permits include structures (e.g., piers,
wharfs, breakwaters, bulkheads, jetties, weirs, transmission lines) and work such as dredging or
disposal of dredged material, or excavation, filling, or other modifications to the navigable
waters of the United States.

40
41
42
43
44
45
46

Safe Drinking Water Act of 1974 (42 U.S.C. §§ 300(f) et seq.; TN1337) – The SDWA was
enacted to protect the quality of public water supplies and sources of drinking water and
establishes minimum national standards for public water supply systems in the form of
maximum contaminant levels for pollutants, including radionuclides. Other programs established
by the SDWA include the Sole Source Aquifer Program, the Wellhead Protection Program, and
the Underground Injection Control Program. In addition, the Act provides underground sources
of drinking water with protection from contaminated releases and spills.

F-9

1
2
3
4
5

If a nuclear power plant is located within an area designated as being a Sole Source Aquifer
pursuant to Section 1424(e) of the SDWA, the supplemental EIS would be subject to EPA
review. If the EPA review raises concerns that plant operations are not protective of
groundwater quality, specific mitigation recommendations or additional pollution prevention
requirements may be required.

6
7
8
9
10
11
12

Toxic Substances Control Act (15 U.S.C. §§ 2601 et seq.; TN4454) – The Toxic Substances
Control Act (TSCA) regulates the manufacture, processing, distribution, and use of certain
chemicals not regulated by RCRA or other statutes, including asbestos-containing material and
polychlorinated biphenyls. Any TSCA-regulated waste removed from structures (e.g.,
polychlorinated biphenyls-contaminated capacitors or asbestos) or discovered during the
implementation phase (e.g., contaminated media) would be managed in compliance with TSCA
requirements in 40 CFR Part 761 (TN6610).

F.3

14
15
16
17

Executive Orders establish policies and requirements for Federal agencies. Executive Orders
do not have the force of law or regulation. Generally, Executive Orders are applicable to most
Federal agencies, although they may or may not be binding upon independent regulatory
agencies such as the NRC.

18
19
20
21
22
23
24

Executive Order 11514, Protection and Enhancement of Environmental Quality
(35 FR 4247-TN6608) – This Order (regulated by 40 CFR Parts 1500 through 1508; TN6611)
requires Federal agencies to continually monitor and control their activities to (1) protect and
enhance the quality of the environment, and (2) develop procedures to ensure the fullest
practicable provision of timely public information and understanding of the Federal plans and
programs that may have potential environmental impacts so that the views of interested parties
can be obtained.

25
26
27

Executive Order 11593, Protection and Enhancement of the Cultural Environment
(36 FR 8921-TN6609) – This Order directs Federal agencies to locate, inventory, and nominate
qualified properties under their jurisdiction or control to the National Register of Historic Places.

28
29
30
31
32
33

Executive Order 11988, Floodplain Management (42 FR 26951-TN270) – This Order requires
Federal agencies to avoid direct or indirect support of floodplain development whenever there is
a practicable alternative. A Federal agency is required to evaluate the potential effects of any
actions it may take in a floodplain. Federal agencies are also required to encourage and provide
appropriate guidance to applicants to evaluate the effects of their proposals on floodplains prior
to submitting applications for Federal licenses, permits, loans, or grants.

34
35
36
37
38
39
40
41

Executive Order 11990, Protection of Wetlands (42 FR 26961-TN269) – This Order requires
Federal agencies to avoid any short- or long-term adverse impacts on wetlands, whenever there
is a practicable alternative and to provide opportunity for early public review of any plans or
proposals for new construction in wetlands. Federal agencies are required to evaluate the
potential effects of any actions they may take on wetlands when carrying out their
responsibilities (e.g., planning, regulating, and licensing activities). However, this Executive
Order does not apply to the issuance by Federal agencies of permits, licenses, or allocations to
private parties for activities involving wetlands on non-Federal property.

Environmental Executive Orders

F-10

1
2
3
4
5

Executive Order 12088, Federal Compliance with Pollution Control Standards (43 FR
47707-TN6623), as amended by Executive Order 12580, Superfund Implementation (52 FR
2923-TN6624) – This Order directs Federal agencies to comply with applicable administrative
and procedural pollution controls standards established by, but not limited to, the CAA, the
Noise Control Act, the CWA, the SDWA, the TSCA, and the RCRA.

6
7
8
9
10

Executive Order 12148, Federal Emergency Management (44 FR 43239-TN6614) – This
Order transfers functions and responsibilities associated with Federal emergency management
to the Director of the Federal Emergency Management Agency. The Order assigns the Director
the responsibility to establish Federal policies for, and to coordinate all civil defense and civil
emergency planning, management, mitigation, and assistance functions of, Executive agencies.

11
12
13
14
15
16

Executive Order 12580, Superfund Implementation (52 FR 2923-TN6624), as amended by
Executive Order 13308 (68 FR 37691-TN6625) – This Order delegates to the heads of
Executive Departments and agencies the responsibility of undertaking remedial actions for
releases or threatened releases that are not on the National Priorities List, and removal actions,
other than emergencies, where the release is from any facility under the jurisdiction or control of
Executive Departments and agencies.

17
18
19

Executive Order 12656, Assignment of Emergency Preparedness Responsibilities
(53 FR 47491-TN6626) – This Order assigns emergency preparedness responsibilities to
Federal departments and agencies.

20
21
22
23
24
25
26
27
28

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations (59 FR 7629-TN1450) – This Order calls for
Federal agencies to address environmental justice in minority populations and low-income
populations, and directs Federal agencies to identify and address, as appropriate,
disproportionately high and adverse health or environmental effects of their programs, policies,
and activities on minority and low-income populations. In response to this Executive Order, the
NRC has issued a final policy statement on the “Treatment of Environmental Justice Matters in
NRC Regulatory and Licensing Actions” (69 FR 52040-TN1009) and environmental justice
procedures to be followed in NEPA documents.

29
30
31
32
33

Executive Order 13007, Indian Sacred Sites (61 FR 26771-TN6629) – This Order directs
Federal agencies, to the extent permitted by law and not inconsistent with agency missions, to
avoid adverse effects on sacred sites and to provide access to those sites to Native Americans
for religious practices. The Order directs agencies to plan projects and provide protection of and
access to sacred sites to the extent compatible with the project.

34
35
36
37
38
39
40

Executive Order 13045, Protection of Children from Environmental Health Risks and
Safety Risks (62 FR 19885-TN6630), as amended by Executive Order 13229 (66 FR 52013TN6631), as amended by Executive Order 13296 (68 FR 19931-TN6632) – This Order
requires Federal Executive branch agencies to make it a high priority to identify and assess
environmental health risks and safety risks that may disproportionately affect children and to
ensure that its policies, programs, activities, and standards address disproportionate risks to
children that result from environmental health or safety risks.

41
42
43
44

Executive Order 13112, Invasive Species (64 FR 6183-TN4477) – This Order directs Federal
agencies to act to prevent the introduction of or to monitor and control, invasive (non-native)
species, to provide for restoration of native species, to conduct research, to promote
educational activities, and to exercise care in taking actions that could promote the introduction

F-11

1
2

or spread of invasive species. During the implementation phase, rehabilitation of disturbed
areas would be accomplished by reseeding or revegetating areas with native plants and trees.

3
4
5
6
7
8

Executive Order 13123, Greening the Government through Efficient Energy Management
(64 FR 30851-TN6634) – This Order sets goals for agencies to reduce greenhouse gas
emissions from facility energy use, reduce energy consumption per gross square foot of
facilities, reduce energy consumption per gross square foot or unit of production, expand use of
renewable energy, reduce the use of petroleum within facilities, reduce source energy use, and
reduce water consumption and associated energy use.

9
10
11
12
13
14
15
16

Executive Order 13175, Consultation and Coordination with Indian Tribal Governments
(65 FR 67249-TN4846) – This Order directs Federal agencies to establish regular and
meaningful consultation and collaboration with tribal governments in the development of Federal
policies that have tribal implications, to strengthen U.S. government-to-government relationships
with American Indian Tribes, and to reduce the imposition of unfunded mandates on tribal
governments. On January 9, 2017, the NRC published its Tribal Policy Statement, which
describes best practices and principles in conducting the agency's government-to-government
interactions with American Indian and Alaska Native tribes (82 FR 2402-TN5500).

17
18
19
20
21
22
23
24
25
26

Executive Order 13990, Protecting Public Health and the Environment and Restoring
Science to Tackle the Climate Crisis (86 FR 7037-TN7028) – This Order lays out a broad
policy related to science, public health, environmental protection, environmental justice, and
associated job creation. The Order directs Federal agency heads to “immediately” review
actions taken during the Trump Administration “that are or may be inconsistent with, or present
obstacles to,” this policy and to develop and submit to certain Administration officials lists of
planned agency actions to rectify the identified issues. The Order also establishes an
Interagency Working Group on the Social Cost of Greenhouse Gases and revokes or
temporarily suspends a number of prior Orders and other White House issuances related to
environmental, infrastructure, and energy issues that were issued by President Trump.

27
28
29
30
31
32
33
34
35

Executive Order 14008, Tackling the Climate Crisis at Home and Abroad (86 FR 7619TN7027) – This Order addresses a number of areas related to climate change, including making
climate change issues central to U.S. foreign policy and national security and pursuing various
government-wide domestic initiatives. The aspects of the Order with the most direct applicability
to the NRC are the provisions addressing the sustainability and climate-related resilience of a
Federal agency’s own operations. For example, the NRC will submit a draft action plan
describing steps the agency can take with regard to its facilities and operations to bolster
adaptation and increase resilience to the impacts of climate change and will also release
publicly progress reports as updates on the agency’s implementation efforts.

36
37
38
39
40
41
42
43
44
45

Executive Order 14096, Revitalizing Our Nation’s Commitment to Environmental Justice
for All (88 FR 25251) – This Order builds on and supplements the foundational efforts of
Executive Order 12898, “Federal Actions To Address Environmental Justice in Minority
Populations and Low-Income Populations,” issued in 1994, to address environmental justice. It
calls for a government-wide approach to environmental justice for all and establishment of a
new White House Office of Environmental Justice within the existing Council on Environmental
Quality (CEQ). The Order also directs Federal agencies in the executive branch to develop
Environmental Justice Strategic Plans that are tied to specific performance and accountability
measures outlined in Section 4 of Executive Order 14096. The Order also states, “Independent
regulatory agencies are strongly encouraged to comply with the provisions of this order and to

F-12

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2

provide notice to the Chair of CEQ of their intention to do so. The Chair of CEQ shall make such
notices publicly available and maintain a list online of such agencies.”

F.4

4
5
6

The AEA, as amended, allows the NRC to issue licenses for commercial power reactors to
operate up to 40 years. This license is based on adherence of the licensee to the NRC’s
regulations that are set forth in Chapter 1 of Title 10 of the CFR.

U.S. Nuclear Regulatory Commission Regulations and Guidance

7
8
9
10
11

The new nuclear reactor license process includes two reviews: an environmental review and a
safety review. The reviews are based on the regulations published in 10 CFR Part 51 (TN250)
for the environmental review and 10 CFR Part 50 (TN249) or Part 52 (TN251) for the safety
review. These regulations prescribe the format and content of license applications, as well as,
the methods and criteria used by NRC staff in evaluating these applications.

The environmental review relies upon the following regulations and guidance:

13
14
15

• Code of Federal Regulations – The scope of the environmental review is based on the
regulations provided in 10 CFR Part 51 (TN250), Environmental Protection Regulations for
Domestic Licensing and Related Regulatory Functions.

16
17
18
19
20

• Preparation of Environmental Reports for Nuclear Power Stations (Regulatory Guide 4.2;
NRC 2024-TN7081) – This document outlines the format and content to be used by the
applicant to discuss the environmental aspects of its license application. It also defines the
information and analyses the applicant must include in its environmental report submitted as
part of the application.

21
22
23
24

• Standard Review Plan for Environmental Reviews for Nuclear Power Plants (NUREG-1555)
– This document provides guidance to the staff in implementing provisions of 10 CFR
Part 51 (TN250), Environmental Protection Regulations for Domestic Licensing and Related
Regulatory Functions, related to new site/plant applications.

25
26
27
28

• “Interim Staff Guidance Environmental Considerations Associated with Micro-reactors”
(COL-ISG-029; NRC 2020-TN6710) – This document provides supplemental guidance to
assist the NRC staff in determining the scope and scale of environmental reviews of
microreactor applications.

29
30
31
32
33
34

• Generic Environmental Impact Statement for Licensing New Nuclear Reactors (NR GEIS)
(NUREG-2249; NRC 2021-TN7080) – This document discusses the environmental impacts
from new nuclear reactor licensing that are common to all or most nuclear power facilities.
The GEIS allows the applicant and the NRC to focus on environmental issues specific to
each site seeking a renewed operating license. The staff’s review results in a projectspecific supplement to the GEIS for each plant site.

F.5

State Laws, Regulations, and Other Requirements

36
37
38
39
40
41
42

The AEA authorizes States to establish programs to assume NRC regulatory authority for
certain activities (the NRC’s Agreement State Program). The New York State Department of
Labor and Department of Environmental Conservation, for example, have established
requirements under this Agreement State Program. New York State Department of Labor has
jurisdiction in New York over commercial and industrial uses of radioactive material. Under the
New York Agreement State Program, New York State Department of Labor and Department of
Environmental Conservation has jurisdiction over discharges of radioactive material to the

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2
3
4
5

environment, including releases to the air and water, and the disposal of radioactive wastes in
the ground. In addition, States have enacted their own laws to protect public health and safety,
and the environment. State laws may supplement or implement various Federal laws for
protection of air, water quality, and groundwater. State laws may also address solid waste
management programs, locally rare or endangered species, and historic and cultural resources.

6
7
8
9
10

In addition, the CWA allows for primary enforcement and administration through State agencies,
provided the State program (1) is at least as stringent as the Federal program and (2) conforms
to the CWA. The primary CWA mechanism for controlling water pollution is the requirement that
direct dischargers obtain an NPDES permit or, in the case of States in which the authority has
been delegated from the EPA, a State permit.

11
12
13
14
15

One important difference between Federal regulations and certain State regulations is the
definition of “waters” regulated by the State. Certain State regulations may include underground
waters, while the CWA only regulates the navigable waters of the United States. For example, a
State permit is required under New York State law for all discharges to both surface waters and
groundwater.

F.6

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18
19
20

Certain environmental requirements, including some discussed earlier, may have been
delegated to State authorities for implementation, enforcement, or oversight. Table F-1 provides
a list of representative State environmental requirements that may affect new nuclear reactor
applications for nuclear power plants.

Table F-1 State Environmental Requirements

State Environmental Requirements

Law/Regulation

Requirements

Air Quality Protection
Title V Permit Rules

Establishes the policies and procedures by which a State will administer the
Title V permit program under the CAA. Requires Title V sources to apply for
and obtain a Title V permit prior to operation of the source facility.
Permits to Install New
Requires a permit prior to the installation of a new source of air pollutants or
Sources of Pollution
the modification of an air contaminant source. Discusses exemptions and
conditions under which approval will be granted. Also requires an impact
analysis to determine if the air contaminant source will cause or contribute to
violations of the NAAQSs.
Air Permits to Operate and Requires a permit prior to the operation or use of any air contaminant source
Variances
in violation of any applicable air pollution control law, unless a variance has
been applied for and obtained from the State agency.
Accidental Release
Prevention Program

General Conformity Rules

Requires the owner or operator of a stationary source, that has more than a
threshold quantity of a regulated substance, to comply with all the provisions
of the rule, including creating a hazard assessment, risk management plan, a
prevention program, and an emergency response program.
Rules on “general conformity” are mandated by the CAA to ensure that
Federal actions do not contribute to air quality violations within the State.
Discusses which Federal actions are subject to the conformity requirements,
the procedures for conformity analysis, public participation/consultation, and
the final conformity determination.

F-14

Table F-1

State Environmental Requirements (Continued)

Law/Regulation
Requirements
Water Resources Protection
National Pollutant
Requires a permit prior to the discharge of pollutants from any point source
Discharge Elimination
into waters of the United States. Each permit holder must comply with
System Permits
authorized discharge levels, monitoring requirements, and other appropriate
requirements in the permit.
Permits to Install New
Requires a permit prior to the installation of a new source of water pollutants
Sources of Pollution
or the modification of any pollutant discharge source.
Water Quality Standards
Establishes water quality standards for surface waters in the State, including
beneficial use designations, numeric water quality criteria, and the antidegradation waterbody classification system. Water quality standards are
enforced through the NPDES permit.
Section 401 Water Quality Requires a Section 401 water quality certification and payment of applicable
Certifications
fees before the issuance of any Federal permit or license to conduct any
activity that may result in discharges to waters of the State.
Public Water Systems
Requires a public water system license prior to operating or maintaining a
Licenses to Operate
public water system.
Design, Construction,
Establishes performance standards and upgrading requirements for
Installation, and Upgrading underground storage tanks containing petroleum (e.g., diesel fuel) or other
for Underground Storage
regulated substances. Requires an installation or upgrading permit for each
Tank Systems
location where such installation or upgrading is to occur prior to beginning
either an installation or upgrading of a tank or piping comprising an
underground storage tank system.
Registration of
Establishes annual registration requirements for underground storage tanks
Underground Storage Tank containing petroleum or other regulated substances.
System
Flammable and
Requires a permit to install, remove, repair, or alter a stationary tank for the
Combustible Liquids
storage of flammable or combustible liquids or modify or replace any line or
dispensing device.
Waste Management and Pollution Prevention
Generator Standards
Requires any person who generates waste to determine if that waste is
hazardous. Requires a generator identification number from the EPA or State
agency prior to treatment, storage, disposal, transport, or offer for transport
of hazardous waste.
Licensing Requirements for Requires an annual license for any municipal solid waste landfill, industrial
Solid Waste, Construction, solid waste landfill, residual solid waste landfill, compost facility, transfer
and Demolition Debris
facility, infectious waste treatment facility, or solid waste incineration facility
Facilities
prior to operation. New facilities must obtain a permit to install, prior to
construction. Also, requires a license to establish, modify, operate, or
maintain a construction and demolition debris facility.
Radiation Generator and
Requires completion of a low-level radioactive waste generator report within
Broker Reporting
60 days of beginning to generate low-level waste. Also requires each
Requirements
generator to submit an annual report about the state of low-level waste
activities in their facility and pay applicable fees.
Hazardous Waste
Requires operation permits for any new or existing hazardous waste facility.
Management System
Permits

F-15

Table F-1

State Environmental Requirements (Continued)

Law/Regulation
Requirements
Emergency Planning and Response
Hazardous Chemical
Requires the submission of Material Safety Data Sheets and an annual
Reporting
Emergency and Hazardous Chemical Inventory to local emergency response
officials for any hazardous chemicals that are produced, used, or stored at
the facility in an amount that equals or exceeds the threshold quantity.
Emergency Planning
Requires any facility that has an extremely hazardous substance present in
Requirements of Subject
an amount equal to, or exceeding the threshold planning quantity, to notify
Facilities
the emergency response commission and the local emergency planning
committee within 60 days after onsite storage begins. Also requires the
designation of a facility representative who will participate in the local
emergency planning process as a facility emergency coordinator.
Toxic Chemical Release
Establishes reporting requirements and a schedule for each toxic chemical
Reporting
known to be manufactured (including imported), processed, or otherwise
used in excess of an applicable threshold quantity. Applies only to facilities of
a certain classification.
Biotic Resources Protection
State Endangered Plant
Establishes criteria for identifying threatened or endangered species of native
Species Protection
plants and prohibits injuring or removing endangered species without
permission.
State Endangered Fish and Establishes and requires periodic updates to a State list of endangered fish
Wildlife Species Protection and wildlife species.
Permits for Impacts on
Requires a general or individual isolated wetland permit prior to engaging in
Isolated Wetlands
an activity that involves the filling of an isolated wetland.
Cultural Resources Protection
State Registry of
Establishes a State registry of archaeological landmarks. Prohibits any
Archaeological Landmarks person from excavating or destroying such land, or from removing skeletal
remains or artifacts from any land, placed on the registry without first
notifying the State Historic Preservation Office.
Survey and Salvage;
Directs State departments, agencies, and political subdivisions to cooperate
Discoveries; Preservation in the preservation of archaeological and historic sites and the recovery of
scientific information from such sites. Also, requires State agencies and
contractors performing work on public improvements to cooperate with
archaeological and historic survey and salvage efforts and to notify the State
historic preservation office about archaeological discoveries.

F.7

Operating Permits and Other Requirements

2
3
4

Several operating permit applications may be prepared and submitted, and regulatory approval
and/or permits would be received, prior to license approval by the NRC. Table F-2 lists
representative Federal, State, and local permits.

F-16

Table F-2 Federal, State, and Local Permits and Other Requirements
License, Permit, or Other Responsible
Required Approval
Agency
Air Quality Protection
Title V Operating Permit: EPA or State
Required for sources that agency
are not exempt and are
major sources, affected
sources subject to the
Acid Rain Program,
sources subject to new
source performance
standards, or sources
subject to National
Emission Standards for
Hazardous Air Pollutants.
Risk Management Plan: EPA or State
Required for any
agency
stationary source that has
a regulated substance
(e.g., chlorine, hydrogen
fluoride, nitric acid) in any
process (including
storage) in a quantity that
is over the threshold level.
CAA Conformity
EPA or State
Determination: Required agency
for each criteria pollutant
(i.e., sulfur dioxide,
particulate matter, carbon
monoxide, ozone, nitrogen
dioxide, and lead) where
the total of direct and
indirect emissions in a
nonattainment or
maintenance area caused
by a Federal action would
equal or exceed threshold
rates.
Water Resources Protection
NPDES Permit:
EPA or State
Construction Site
agency
Stormwater: Required
before making point
source discharges of
stormwater from a
construction project that
disturbs more than
2 hectares (5 acres) of
land.

Authority

Relevance and Status

CAA, Title V, Sections 501−507
(U.S.C., Title 42, §§ 7661–7661f
[42 U.S.C. §§ 7661–7661f;
TN1141])

Nuclear power plants are
subject to 40 CFR Part
61, Subpart H (TN3289),
“National Emissions
Standards for Emissions
of Radionuclides,” which
is included in the terms
and conditions of the Title
V Operating Permit.

CAA, Title 1, Section 112(R)(7)
(42 U.S.C. § 7412-TN7014)

These regulated
substances stored in
quantities that exceed the
threshold levels would
require a risk
management plan.

CAA, Title 1, Section 176(c)
(42 U.S.C. § 7506-TN4856)

CAA conformity
determination would be
required at nuclear power
plants located in
nonattainment areas with
NAAQSs for criteria
pollutants or maintenance
areas for any criteria
pollutant that would be
emitted as a result of new
nuclear reactor licensing.

CWA (33 U.S.C. §§ 1251
et seq.; TN662); 40 CFR
Part 122 (TN2769)

Any plant refurbishment
involving construction of
more than 2 hectares
(5 acres) of land would
require a Stormwater
Pollution Prevention Plan
and construction site
stormwater discharge
permit.

F-17

Table F-2

Federal, State, and Local Permits and Other Requirements (Continued)

License, Permit, or Other Responsible
Required Approval
Agency
Authority
NPDES Permit: Industrial EPA or State CWA (33 U.S.C. §§ 1251
Facility Stormwater:
agency
et seq.; TN662); 40 CFR Part
Required before making
122 (TN2769)
point source discharges of
stormwater from an
industrial site.

NPDES Permit: Process EPA or State
Water Discharge:
agency
Required before making
point source discharges of
industrial process
wastewater.
Spill Prevention Control
EPA or State
and Countermeasures
agency
Plan: Required for any
facility that could
discharge diesel fuel in
harmful quantities into
navigable waters or onto
adjoining shorelines.
CWA Section 401 Water EPA or State
Quality Certification:
agency
Required to be submitted
to the agency responsible
for issuing any Federal
license or permit to
conduct an activity that
may result in a discharge
of pollutants into waters of
a State.
New Underground
EPA or State
Storage Tanks System
agency
Registration: Required
within 30 days of bringing
a new underground
storage tank system into
service.
Aboveground Storage
State Fire
Tank: A permit is required Marshal
to install, remove, repair,
or alter any stationary tank
for the storage of
flammable or combustible
liquids.

CWA (33 U.S.C. §§ 1251
et seq.; TN662); 40 CFR Part
122 (TN2769)

CWA (33 U.S.C. §§ 1251
et seq.; TN662); 40 CFR
Part 112 (TN1041)

Relevance and Status
Stormwater would be
discharged from the
nuclear power plants
during operations.
Stormwater would
discharge through
existing outfalls covered
by a permit.
Process industrial
wastewater would be
discharged through
existing outfalls covered
by the permit.
A Spill Prevention Control
and Countermeasures
Plan is required at
nuclear power plants
storing large volumes of
diesel fuel and/or other
petroleum products.

CWA, Section 401 (33 U.S.C. § Certification for operation
1341-TN4764); Chapters 119
of a nuclear power plant
and 6111
may require a Federal
license or permit (e.g., a
CWA Section 404
Permit).

RCRA, as amended, Subtitle I
(42 U.S.C. §§ 6991a−6991i;
TN1281); 40 CFR 280.22
(TN6619)

Required if new
underground storage tank
systems would be
installed at a nuclear
power plant.

Required if new
aboveground diesel fuel
storage tanks would be
installed at a nuclear
power plant.

F-18

Table F-2

Federal, State, and Local Permits and Other Requirements (Continued)

License, Permit, or Other Responsible
Required Approval
Agency
Authority
Waste Management and Pollution Prevention
Registration and
EPA or State RCRA, as amended (42 U.S.C.
Hazardous Waste
agency
§§ 6901 et seq.; TN1281),
Generator Identification
Subtitle C
Number: Required before
a person who generates
over 100 kg (220 lb) per
calendar month of
hazardous waste ships
the hazardous waste
offsite.
Hazardous Waste Facility EPA or State RCRA, as amended (42 U.S.C.
Permit: Required if
agency
§§ 6901 et seq.; TN1281),
hazardous waste will
Subtitle C
undergo nonexempt
treatment by the
generator, be stored
onsite for longer than
90 days by the generator
of 1,000 kg (2,205 lb) or
more of hazardous waste
per month, be stored
onsite for longer than
180 days by the generator
of between 100 and 1,000
kg (220 and 2,205 lb) of
hazardous waste per
month, disposed of onsite,
or be received from offsite
for treatment or disposal.
Emergency Planning and Response
List of Material Safety
State and local EPCRA, Section 311 (42 U.S.C.
Data Sheets: Submission emergency
§ 11021; TN6603);
of a list of Material Safety planning
40 CFR 370.20 (TN6612)
Data Sheets is required
agencies
for hazardous chemicals
(as defined in 29 CFR
Part 1910-TN654) that are
stored onsite in excess of
their threshold quantities.
Annual Hazardous
State and local EPCRA, Section 312 (42 U.S.C.
Chemical Inventory
emergency
§ 11022; TN6603);
Report: The report must response
40 CFR 370.25 (TN6612)
be submitted when
agencies; local
hazardous chemicals
fire department
have been stored at a
facility during the
preceding year in amounts
that exceed threshold
quantities.

F-19

Relevance and Status
Generators of hazardous
waste must notify the
EPA that the wastes exist
and require management
in compliance with RCRA.

Hazardous wastes are
usually not disposed of
onsite at nuclear power
plants. Hazardous wastes
generated onsite are not
generally stored for more
than 90 days. However,
should a nuclear power
plant store waste onsite
for greater than 90 days
for characterization,
profiling, or scheduling for
treatment or disposal, a
Hazardous Waste Facility
Permit would be required.

Nuclear power plant
operators are required to
submit a list of Material
Safety Data Sheets to
State and local
emergency planning
agencies.

Table F-2

Federal, State, and Local Permits and Other Requirements (Continued)

License, Permit, or Other
Required Approval
List of Material Safety
Data Sheets: Submission
of a list of Material Safety
Data Sheets is required
for hazardous chemicals
(as defined in 29 CFR
Part 1910-TN654) that are
stored onsite in excess of
their threshold quantities.
Annual Hazardous
Chemical Inventory
Report: The report must
be submitted when
hazardous chemicals
have been stored at a
facility during the
preceding year in amounts
that exceed threshold
quantities.

Responsible
Agency
Authority
State and local EPCRA, Section 311 (42 U.S.C.
emergency
§ 11021; TN6603);
planning
40 CFR 370.20 (TN6612)
agencies

Relevance and Status
Nuclear power plant
operators are required to
submit a list of Material
Safety Data Sheets to
State and local
emergency planning
agencies.

State and local EPCRA, Section 312 (42 U.S.C.
emergency
§ 11022; TN6603);
response
40 CFR 370.25 (TN6612)
agencies; local
fire department

Annual Hazardous
Chemical Inventory
Report: The report must
be submitted when
hazardous chemicals
have been stored at a
facility during the
preceding year in amounts
that exceed threshold
quantities.

State and local
emergency
response
agencies; local
fire department

Notification of Onsite
Storage of an Extremely
Hazardous Substance:
Submission of the
notification is required
within 60 days after onsite
storage begins of an
extremely hazardous
substance in a quantity
greater than the threshold
planning quantity.
Annual Toxics Release
Inventory Report:
Required for facilities that
have 10 or more full-time
employees and are
assigned certain Standard
Industrial Classification
Codes.
Transportation of
Radioactive Wastes and
Conversion Products

State and local
emergency
response
agencies

EPA or State
agency

If hazardous chemicals
have been stored at a
nuclear power plant
during the preceding year
in amounts that exceed
threshold quantities, then
plant operators would be
required to submit an
annual Hazardous
Chemical Inventory
Report.
EPCRA, Section 312 (42 U.S.C. If hazardous chemicals
§ 11022; TN6603);
have been stored at a
40 CFR 370.25 (TN6612)
nuclear power plant
during the preceding year
in amounts that exceed
threshold quantities, then
plant operators would be
required to submit an
annual Hazardous
Chemical Inventory
Report.
EPCRA, Section 304 (42 U.S.C. If an extremely hazardous
§ 11004; TN6603);
substance will be stored
40 CFR 355.30 (TN5493)
at a nuclear power plant
in a quantity greater than
the threshold planning
quantity, plant operators
would prepare and submit
the Notification of Onsite
Storage of an Extremely
Hazardous Substance.
EPCRA, Section 313 (42 U.S.C. If required, nuclear power
§ 11023; TN6603); 40 CFR Part plant operators would
372 (TN6613)
prepare and submit a
Toxics Release Inventory
Report to the EPA.

U.S.
Hazardous Materials
When shipments of
Department of Transportation Act (49 U.S.C.
radioactive materials are
Transportation §§ 5101 et seq.; TN6605); AEA, made, nuclear power

F-20

Table F-2

Federal, State, and Local Permits and Other Requirements (Continued)

License, Permit, or Other Responsible
Required Approval
Agency
Packaging, Labeling, and
Routing Requirements for
Radioactive Materials:
Required for packages
containing radioactive
materials that will be
shipped by truck or rail.
Biotic Resource Protection
Threatened and
FWS and
Endangered Species
NMFS
Consultation: Required
between the responsible
Federal agencies and
FWS and/or NMFS to
ensure that the project is
not likely to: (1) jeopardize
the continued existence of
any species listed at the
Federal or State level as
endangered or
threatened, or (2) result in
destruction of critical
habitat of such species.
Essential Fish Habitat
NMFS
Consultation: Required
between the responsible
Federal agency and
NMFS to ensure that
Federal actions
authorized, funded, or
undertaken do not
adversely affect essential
fish habitat.
CWA Section 404 (Dredge USACE
and Fill) Permit: Required
to place dredged or fill
material into waters of the
United States, including
areas designated as
wetlands, unless such
placement is exempt or
authorized by a
nationwide permit or a
regional permit; a notice
must be filed if a
nationwide or regional
permit applies.
Cultural Resources Protection
Archaeological and
State Historic
Historical Resources
Preservation
Consultation: Required
Officer and/or
before a Federal agency Tribal Historic

Authority
as amended (42 U.S.C. §§ 2011
et seq.; TN663); 49 CFR Part
172 (TN6616),
Part 173 (TN298), Part 174
(TN6622), Part 177 (TN6620),
and Part 397 (TN6621)

Relevance and Status
plant operators would
comply with U.S.
Department of
Transportation
packaging, labeling, and
routing requirements.

ESA of 1973, as amended
(16 U.S.C. §§ 1531 et seq.;
TN1010)

For actions that may
affect listed species or
designated critical
habitat, the NRC would
consult with the FWS
and/or NMFS under
Section 7 of the ESA.

Magnuson-Stevens Fishery
Conservation and Management
Act, as amended (16 U.S.C.
§§ 1801–1884; TN1061)

For actions that may
adversely affect essential
fish habitat, the NRC
would consult with NMFS
in accordance with 50
CFR Part 600, Subpart J
(TN1342).

CWA (33 U.S.C. §§ 1251
et seq.; TN662); 33 CFR Part
323 (TN4827) and Part 330
(TN4318)

Dredging or placement of
fill material into wetlands
within the jurisdiction of
the USACE at a nuclear
power plant would require
a Section 404 permit.

NHPA of 1966, as amended (54
U.S.C. §§ 300101 et seq.;
TN4157); Archeological and
Historical Preservation Act of

The NRC would consult
with the State and/or
Tribal Historic
Preservation Officers and

F-21

Table F-2

Federal, State, and Local Permits and Other Requirements (Continued)

License, Permit, or Other Responsible
Required Approval
Agency
Authority
approves a project in an Preservation
1974 (54 U.S.C. §§ 312501
area where archaeological Officer
et seq.; TN4844); Antiquities Act
or historic resources might
of 1906 (54 U.S.C. §§ 320301–
be located.
320303 and 18 U.S.C.
§ 1866(b); TN6602);
Archaeological Resources
Protection Act of 1979, as
amended (16 U.S.C.
§§ 470aa−mm; TN1687)

Relevance and Status
representative American
Indian Tribes regarding
the impacts of licensing
new nuclear reactors and
the results of
archaeological and
architectural surveys of
nuclear power plant sites.

1
2

F.8

Emergency Management and Response Laws, Regulations, and Executive
Orders

3
4
5
6
7

This section discusses the response laws, regulations, and Executive Orders that address the
protection of public health and worker safety and require the establishment of emergency plans.
These laws, regulations, and Executive Orders relate to the operation of nuclear power plants.
To make things easier for readers, certain items are repeated from previous sections in this
appendix.

F.9

Federal Emergency Management Response Laws

9
10
11
12
13
14
15
16
17
18
19
20

Emergency Planning and Community Right-to-Know Act of 1986 (42 U.S.C. §§ 11001
et seq.; TN6603) (also known as “SARA Title III”) – EPCRA, which is the major amendment
to CERCLA (42 U.S.C. § 9601; TN6592), establishes the requirements for Federal, State, and
local governments, American Indian Tribes, and industry regarding emergency planning and
“Community Right-to-Know” reporting on hazardous and toxic chemicals. The “Community
Right-to-Know” provisions increase the public’s knowledge and access to information about
chemicals at individual facilities, their uses, and releases into the environment. States and
communities working with facilities can use the information to improve chemical safety and
protect public health and the environment. This Act requires emergency planning and notice to
communities and government agencies concerning the presence and release of specific
chemicals. The EPA implements this Act under regulations found in 40 CFR Part 355 (TN5493),
Part 370 (TN6612), and Part 372 (TN6613).

21
22
23
24

Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(42 U.S.C. § 9604(I); TN6592 (also known as “Superfund”) – This Act provides authority for
Federal and State governments to respond directly to hazardous substance incidents. The Act
requires reporting of spills, including radioactive spills, to the National Response Center.

25
26
27
28
29
30
31
32
33

Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988 (42 U.S.C.
§ 5121; TN6638) – This Act, as amended, provides an orderly, continuing means of providing
Federal government assistance to State and local governments in managing their
responsibilities to alleviate suffering and damage resulting from disasters. The President, in
response to a State governor’s request, may declare an “emergency” or “major disaster” to
provide Federal assistance under this Act. The President, in Executive Order 12148 (44 FR
43239-TN6614), delegated all functions except those in Sections 301, 401, and 409 to the
Director of the Federal Emergency Management Agency. The Act provides for the appointment
of a Federal coordinating officer who will operate in the designated area with a State

F-22

1
2

coordinating officer for the purpose of coordinating State and local disaster assistance efforts
with those of the Federal government.

3
4
5
6
7
8
9
10
11

Justice Assistance Act of 1984 (42 U.S.C. § 3701−3799; TN6639) – This Act establishes
emergency Federal law enforcement assistance to State and local governments in responding
to a law enforcement emergency. The Act defines the term “law enforcement emergency” as an
uncommon situation that requires law enforcement, that is or threatens to become of serious or
epidemic proportions, and with respect to which State and local resources are inadequate to
protect the lives and property of citizens or to enforce the criminal law. Emergencies that are not
of an ongoing or chronic nature (for example, the Mount St. Helens volcanic eruption) are
eligible for Federal law enforcement assistance including funds, equipment, training, intelligence
information, and personnel.

12
13
14
15
16
17

Price-Anderson Act (42 U.S.C. § 2210; TN4522) – The Price-Anderson Act provides insurance
protection to victims of a nuclear accident. The main purpose of the Act is to partially indemnify
the nuclear industry against liability claims arising from nuclear incidents, while still ensuring
compensation coverage for the general public. The Act establishes a no-fault insurance-type
system in which the first $12.6 billion (as of 2011) is industry-funded as described in the Act
(any claims above the $12.6 billion would be covered by the Federal government).

18
19
20
21

The Act requires NRC licensees and U.S. Department of Energy contractors to enter into
agreements of indemnification to cover personal injury and property damage to those harmed
by a nuclear or radiological incident, including the costs of incident response or precautionary
evacuation, costs of investigating and defending claims, and settling suits for such damages.

F.10 Federal Emergency Management and Response Regulations

23
24
25
26
27

Quantities of Radioactive Materials Requiring Consideration of the Need for an
Emergency Plan for Responding to a Release (10 CFR 30.72, Schedule C; TN4881) – This
section of the regulations provides a list that is the basis for both the public and private sector to
determine whether the radiological materials they handle must have an emergency response
plan for unscheduled releases.

28
29
30
31
32
33
34
35
36
37
38
39
40
41

Occupational Safety and Health Administration Emergency Response, Hazardous Waste
Operations, and Worker Right-to-Know (29 CFR Part 1910; TN654) – This regulation
establishes OSHA requirements for employee safety in a variety of working environments. It
addresses employee emergency and fire prevention plans (Section 1910.38), hazardous waste
operations and emergency response (Section 1920.120), and hazards communication
(Section 1910.1200) to make employees aware of the dangers they face from hazardous
materials in their workplace. These regulations do not directly apply to Federal agencies.
However, Section 19 of the Occupational Safety and Health Act (29 U.S.C. § 668) requires all
Federal agencies to have occupational safety programs “consistent” with Occupational Safety
and Health Act standards. There is a Memorandum of Understanding between the NRC and
OSHA (NRC 2013-TN10165). The memorandum states its purpose is to “to delineate the
general areas of responsibility of each agency, to describe generally the efforts of the agencies
to achieve worker protection at facilities licensed by the NRC, and to provide guidelines for
coordination of activities between the two agencies regarding occupational safety and health.

42
43
44

Emergency Management and Assistance (44 CFR Section 1.1; TN6615) – This regulation
contains the policies and procedures for the Federal Emergency Management Act, National
Flood Insurance Program, Federal Crime Insurance Program, Fire Prevention and Control

F-23

1
2

Program, Disaster Assistance Program, and Preparedness Program, including radiological
planning and preparedness.

3
4
5
6
7

Hazardous Materials Tables and Communications, Emergency Response Information
Requirements (49 CFR Part 172; TN6616) – This regulation defines the regulatory
requirements for marking, labeling, placarding, and documenting hazardous material shipments.
The regulation also specifies the requirements for providing hazardous material information and
training.

F.11 Emergency Management and Response Executive Orders

9
10
11
12
13
14

Executive Order 12148, Federal Emergency Management (44 FR 43239-TN6614) – This
Order transfers functions and responsibilities associated with Federal emergency management
to the Director of the Federal Emergency Management Agency. The Order assigns the Director
the responsibility to establish Federal policies and to coordinate all civil defense and civil
emergency planning for the management, mitigation, and assistance functions of Executive
agencies.

15
16
17

Executive Order 12656, Assignment of Emergency Preparedness Responsibilities
(53 FR 47491-TN6626) – This Order assigns emergency preparedness responsibilities to
Federal departments and agencies.

18
19
20
21
22

Executive Order 12938, Proliferation of Weapons of Mass Destruction (59 FR 59099TN6640) – This Order states that the proliferation of nuclear, biological, and chemical weapons
(“weapons of mass destruction”) and the means of delivering such weapons constitutes an
unusual and extraordinary threat to the national security, foreign policy, and economy of the
United States, and that a national emergency would be declared to deal with that threat.

23
24

F.12 Consultations with Agencies and Federally Recognized American Indian
Nations

25
26
27
28
29
30
31
32
33
34
35
36

Certain laws, such as the ESA (16 U.S.C. §§ 1531 et seq.; TN1010), the Fish and Wildlife
Coordination Act (16 U.S.C. §§ 661 et seq.; TN4467), and the NHPA (54 U.S.C.
§§ 300101 et seq.; TN4157), require consultation and coordination by the NRC with other
governmental entities, including other Federal, State, and local agencies and federally
recognized American Indian Tribes. These consultations must occur on a timely basis and are
generally required before any land disturbance can begin. Most of these consultations are
related to biotic resources, historic properties, cultural resources, and recognizes NRC’s Federal
trust responsibility to American Indian Tribes. The biotic resource consultations generally pertain
to the potential for activities to disturb sensitive species or habitats. Cultural resource
consultations relate to the potential for disruption of important cultural resources and
archaeological sites. Consultations with American Indian Tribes are conducted on a
government-to-government basis.

F.13 References

38
39

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for
Protection Against Radiation.” TN283.

40
41

10 CFR Part 30. Code of Federal Regulations, Title 10, Energy, Part 30, “Rules of General
Applicability to Domestic Licensing of Byproduct Material.” TN4881.

F-24

1
2

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of
Production and Utilization Facilities.” TN249.

3
4

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental
Protection Regulations for Domestic Licensing and Related Regulatory Functions.” TN250.

5
6

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses,
Certifications, and Approvals for Nuclear Power Plants.” TN251.

7
8

29 CFR Part 1910. Code of Federal Regulations, Title 29, Labor, Part 1910, “Occupational
Safety and Health Standards.” TN654.

9
10

33 CFR Part 320. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, Part
320, “General Regulatory Policies.” TN424.

11
12
13

33 CFR Part 323. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, Part
323, “Permits for Discharge of Dredged or Fill Material into Waters of the United States.”
TN4827.

14
15

33 CFR Part 330. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, Part
330, “Nationwide Permit Program.” TN4318.

16
17

36 CFR Part 800. Code of Federal Regulations, Title 36, Parks, Forests, and Public Property,
Part 800, “Protection of Historic Properties.” TN513.

18
19

40 CFR Parts 50-99. Code of Federal Regulations, Title 40, Protection of the Environment,
Subchapter C, Parts 50-99, “Air Programs.” TN5264.

20
21

40 CFR Part 61. Code of Federal Regulations, Title 40, Protection of Environment, Part 61,
“National Emission Standards for Hazardous Air Pollutants.” TN3289.

22
23

40 CFR Part 112. Code of Federal Regulations, Title 40, Protection of Environment, Part 112,
“Oil Pollution Prevention.” TN1041.

24
25

40 CFR Part 121. Code of Federal Regulations, Title 40, Protection of Environment, Part 121,
“State Certification of Activities Requiring a Federal License or Permit.” TN6718.

26
27
28

40 CFR Part 122. Code of Federal Regulations, Title 40, Protection of Environment, Part 122,
“EPA Administered Permit Programs: The National Pollutant Discharge Elimination System.”
TN2769.

29
30

40 CFR Part 190. Code of Federal Regulations, Title 40, Protection of Environment, Part 190,
“Environmental Radiation Protection Standards for Nuclear Power Operations.” TN739.

31
32

40 CFR Parts 239–283. Code of Federal Regulations, Title 40, Protection of Environment, Parts
239–283, EPA Regulations Implementing RCRA. TN6618.

33
34
35

40 CFR Part 280. Code of Federal Regulations, Title 40, Protection of Environment, Part 280,
“Technical Standards and Corrective Action Requirements for Owners and Operators of
Underground Storage Tanks (UST).” TN6619.

F-25

1
2

40 CFR Part 355. Code of Federal Regulations, Title 40, Protection of Environment, Part 302,
“Emergency Planning and Notification.” TN5493.

3
4

40 CFR Part 370. Code of Federal Regulations, Title 40, Protection of Environment, Part 370,
“Hazardous Chemical Reporting: Community Right-To-Know.” TN6612.

5
6

40 CFR Part 372. Code of Federal Regulations, Title 40, Protection of Environment, Part 372,
“Toxic Chemical Release Reporting: Community Right-To-Know.” TN6613.

7
8
9

40 CFR Part 761. Code of Federal Regulations, Title 40, Protection of Environment, Part 761,
“Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and
Use Prohibitions.” TN6610.

10
11

40 CFR Parts 1500–1508. Code of Federal Regulations, Title 40, Protection of Environment,
Subchapter A, “National Environmental Policy Act Implementing Regulations.” TN6611.

12
13

44 CFR Part 1. Code of Federal Regulations, Title 44, Emergency Management and
Assistance, Part 1, “Rulemaking, Policy, and Procedures.” TN6615.

14
15

49 CFR Parts 171-177. Code of Federal Regulations, Title 49, Transportation, Subchapter C,
“Hazardous Materials Regulations (49 CFR Parts 171-177).” TN5466.

16
17
18

19
20

49 CFR Part 173. Code of Federal Regulations, Title 49, Transportation, Part 173, “Shippers—
General Requirements for Shipments and Packagings.” TN298.

21
22

49 CFR Part 174. Code of Federal Regulations, Title 49, Transportation, Part 174, “Carriage by
Rail.” TN6622.

23
24

49 CFR Part 177. Code of Federal Regulations, Title 49, Transportation, Part 177, “Carriage by
Public Highway.” TN6620.

25
26

49 CFR Part 397. Code of Federal Regulations, Title 49, Transportation, Part 397,
“Transportation of Hazardous Materials; Driving and Parking Rules.” TN6621.

27
28

50 CFR Part 600. Code of Federal Regulations. Title 50, Wildlife and Fisheries, Part 600,
“Magnuson-Stevens Act Provisions.” TN1342.

29
30

35 FR 4247. March 7, 1970. “Executive Order 11514 of March 5, 1970: Protection and
Enhancement of Environmental Quality.” Federal Register, Office of the President. TN6608.

31
32

36 FR 8921. May 15, 1971. “Executive Order 11593 of May 13, 1971: Protection and
Enhancement of the Cultural Environment.” Federal Register, Office of the President. TN6609.

33
34

42 FR 26951. May 25, 1977. “Executive Order 11988 of May 24, 1977: Floodplain
Management.” Federal Register, Office of the President. TN270.

35
36

42 FR 26961. May 25, 1977. “Executive Order 11990 of May 24, 1977: Protection of Wetlands.”
Federal Register, Office of the President. TN269.
F-26

1
2
3

43 FR 47707. October 17, 1978. “Executive Order 12088 of October 13, 1978: Federal
Compliance with Pollution Control Standards.” Federal Register, Office of the President.
TN6623.

4
5

44 FR 43239. July 24, 1979. “Executive Order 12148 of July 28, 1979: Federal Emergency
Management” Federal Register, Office of the President. TN6614.

6
7

52 FR 2923. January 29, 1987. “Executive Order 12580 of January 23, 1987: “Superfund
Implementation.” Federal Register, Office of the President. TN6624.

8
9
10

53 FR 47491. November 23, 1988. “Executive Order 12656 of November 18, 1988: Assignment
of Emergency Preparedness Responsibilities.” Federal Register, Office of the President.
TN6626.

11
12
13

14
15

59 FR 59099. November 16, 1994. “Executive Order 12938 of November 14, 1994: Proliferation
of Weapons of Mass Destruction.” Federal Register, Office of the President. TN6640.

16
17

61 FR 26771. May 29, 1996. “Executive Order 13007 of May 24, 1996: Indian Sacred Sites.”
Federal Register, Office of the President. TN6629.

18
19
20

62 FR 19885. April 23, 1997. “Executive Order 13045 of April 21, 1997: Protection of Children
from Environmental Health Risks and Safety Risks.” Federal Register, Office of the President.
TN6630.

21
22

64 FR 6183. February 8, 1999. “Executive Order 13112 of February 3, 1999: Invasive Species.”
Federal Register, Office of the President. TN4477.

23
24

64 FR 30851. June 8, 1999. “Executive Order 13123 of June 3, 1999: Greening the Government
Through Efficient Energy Management.” Federal Register, Office of the President. TN6634.

25
26
27

65 FR 67249. November 9, 2000. “Executive Order 13175 of November 6, 2000—Consultation
and Coordination with Indian Tribal Governments.” Federal Register, Office of the President.
TN4846.

28
29
30

66 FR 52013. October 11, 2001. “Executive Order 13229 of October 9, 2001: Amendment to
Executive Order 13045, Extending the Task Force on Environmental Health Risks and Safety
Risks to Children.” Federal Register, Office of the President. TN6631.

31
32
33

68 FR 19931. April 23, 2003. “Executive Order 13296 of April 18, 2003: Amendments to
Executive Order 13045, Protection of Children from Environmental Health Risks and Safety
Risks.” Federal Register, Office of the President. TN6632.

34
35
36

68 FR 37691. June 24, 2003. “Executive Order 13308 of June 20, 2003: Further Amendment to
Executive Order 12580, as amended, Superfund Implementation. Federal Register, Office of the
President. TN6625.

F-27

1
2
3

4
5

82 FR 2402. January 9, 2017. “Tribal Policy Statement.” Federal Register, Nuclear Regulatory
Commission. TN5500.

6
7
8

86 FR 7037. January 25, 2021. “Executive Order 13990 of January 20, 2021: Protecting Public
Health and the Environment and Restoring Science To Tackle the Climate Crisis.” Federal
Register, Office of the President. TN7028.

9
10

86 FR 7619. February 1, 2021. “Executive Order 14008 of January 27, 2021: Tackling the
Climate Crisis at Home and Abroad.” Federal Register, Office of the President. TN7027.

11
12
13

42 U.S.C. § 7412. Clean Air Act Section 112, “Hazardous Air Pollutants.” TN7014.

15
16

42 U.S.C. § 7506. Clean Air Act Section 176, “Limitations on Certain Federal Assistance.”
TN4856.

American Indian Religious Freedom Act, as amended. 42 U.S.C. § 1996 et seq. TN5281.

18
19

Antiquities Act of 1906, as amended. 54 U.S.C. § 320301–320303 and 18 U.S.C. § 1866(b).
TN6602.

20
21

Archaeological Resources Protection Act of 1979, as amended. 54 U.S.C. § 302101 et seq.
TN1687.

22
23

Archeological and Historic Preservation Act of 1974, as amended. 54 U.S.C. § 312501 et seq.
TN4844.

Atomic Energy Act of 1954. 42 U.S.C. § 2011 et seq. Public Law 112-239, as amended. TN663.

Bald and Golden Eagle Protection Act. 16 U.S.C. § 668-668d et seq. TN1447.

Clean Air Act. 42 U.S.C. § 7401 et seq. TN1141.

Coastal Zone Management Act of 1972. 16 U.S.C. § 1451 et seq. TN1243.

28
29

Comprehensive Environmental Response, Compensation, and Liability Act, as amended. 42
U.S.C. § 9601 et seq. TN6592.

30
31

Emergency Planning and Community Right-to-Know Act of 1986. 42 U.S.C. § 11001 et seq.
TN6603.

Endangered Species Act of 1973. 16 U.S.C. § 1531 et seq. TN1010.

Energy Reorganization Act of 1974, as amended. 42 U.S.C. § 5801 et seq. TN4466.

F-28

1
2

Federal Insecticide, Fungicide, and Rodenticide Act, as amended. 7 U.S.C. § 136 et seq.
TN4535.

3
4

Federal Water Pollution Control Act of 1972 (commonly referred to as the Clean Water Act). 33
U.S.C. § 1251 et seq. TN662.

Fish and Wildlife Conservation Act of 1980. 16 U.S.C. § 2901 et seq. TN6604.

Fish and Wildlife Coordination Act, as amended. 16 U.S.C. § 661 et seq. TN4467.

Fixing America’s Surface Transportation Act. 42 U.S.C. § 4370m et seq. TN6392.

Hazardous Materials Transportation Act. 49 U.S.C. § 5101 et seq. TN6605.

Justice Assistance Act of 1984. 42 U.S.C. § 3701–3799. TN6639.

10
11

Low-Level Radioactive Waste Policy Act of 1980. 42 U.S.C. § 2021b et seq. Public Law 96-573.
TN6606.

12
13

Magnuson-Stevens Fishery Conservation and Management Act, Public Law 94-265, as
amended through October 11, 1996. 16 U.S.C. § 1801 et seq. TN1061.

Marine Mammal Protection Act of 1972, as amended. 16 U.S.C. § 1361 et seq. TN4478.

Marine Protection, Research, and Sanctuaries Act of 1972. 33 U.S.C. § 1401 et seq. TN6637.

Migratory Bird Treaty Act of 1918. 16 U.S.C. § 703 et seq. TN3331.

National Historic Preservation Act. 54 U.S.C. § 300101 et seq. TN4157.

Native American Graves Protection and Repatriation Act. 25 U.S.C. § 3001 et seq. TN1686.

Noise Control Act of 1972. 42 U.S.C. § 4901 et seq. TN4294.

20
21
22
23
24
25
26

27
28
29

NRC (U.S. Nuclear Regulatory Commission). 2020. Environmental Considerations Associated
with Micro-Reactors. Final COL-ISG-029, Washington, D.C. ADAMS Accession No.
ML20252A076. TN6710.

30
31
32

NRC (U.S. Nuclear Regulatory Commission). 2024. Generic Environmental Impact Statement
for Advanced Nuclear Reactors, Draft Report for Comment. NUREG-2249, Washington, D.C.
ADAMS Accession No. ML24176A220. TN7080.

F-29

1
2
3

4
5

Nuclear Energy Innovation and Modernization Act. 42 U.S.C. § 2011 Note. Public Law 115-439,
January 14, 2019, 132 Stat. 5565. TN6469.

Nuclear Waste Policy Act of 1982. 42 U.S.C. § 10101 et seq. TN740.

Occupational Safety and Health Act of 1970, as amended. 29 U.S.C. § 651 et seq. TN4453.

Pollution Prevention Act of 1990. 42 U.S.C. § 13101 et seq. TN6607.

Price-Anderson Act of 1957, as amended. 42 U.S.C. § 2210 et seq. TN4522.

10
11

Resource Conservation and Recovery Act of 1976. 42 U.S.C § 6901 et seq. Public Law 94-580,
90 Stat. 2795. TN1281.

12
13

Robert T. Stafford Disaster Relief and Emergency Assistance Act of 1988. 42 U.S.C. § 5121
et seq. TN6638.

Safe Drinking Water Act of 1974, as amended. 42 U.S.C. § 300f et seq. TN1337.

Toxic Substances Control Act, as amended. 15 U.S.C. § 2601 et seq. TN4454.

F-30

APPENDIX G

1
2
3

PLANT PARAMETER ENVELOPE AND SITE PARAMETER ENVELOPE

4
5
6
7

The interdisciplinary team of subject matter experts assigned to prepare the new nuclear
nuclear reactor generic environmental impact statement (GEIS) used the following methodology
to develop the plant parameter envelope (PPE) and site parameter envelope (SPE) values and
assumptions in this appendix:

8
9

• regulatory limits and permitting requirements relevant to the resource as established by
Federal, State, or local agencies

10
11
12

• relevant information obtained from other U.S. Nuclear Regulatory Commission (NRC)
GEISs, including the License Renewal GEIS (NRC 2024-TN10161) and the Continued
Storage GEIS (NRC 2014-TN4117)

13
14

• empirical knowledge gained from conducting evaluations and analyses for past new nuclear
reactor environmental impact statements (EISs)

15
16

• values and assumptions derived from other documents applying a PPE/SPE approach (such
as the National Reactor Innovation Center PPE Report [NRIC 2021-TN6940])

17
18

• subject matter expertise and/or development of calculations and formulas based upon
education and experience with the resource

19
20
21
22

For details about the PPE and SPE values and assumptions, see the applicable resource
section in Chapter 3. The PPE and SPE values and assumptions are used only to support the
findings for Category 1 issues. Category 2 issues do not have PPE and SPE values and
assumptions.

G-1

Table G-1
Parameter
Reactor Site Criteria

Plant Parameter Envelope and Site Parameter Envelope for New Reactors

Values and Assumptions
10 CFR Part 100 (TN282) Subpart B Evaluation Factors for
Stationary Power Reactor Site Applications on or After January
10, 1997

Basis/Methodology
Adherence to siting criteria regulations has been
determined to minimize impacts associated with
environmental review evaluations.

Reactor siting factors to be considered by the applicant shall
include:
1.
2.
3.
Site Size and
Location

1.
2.
3.
4.

G-2
5.

10 CFR 100.20 Factors to be considered when evaluating
sites
10 CFR 100.21 Non-seismic siting criteria
10 CFR 100.23 Geologic and seismic siting criteria
100 ac
Complies with applicable zoning
Consistent with the objectives of any relevant land use plans
Complies with the Coastal Zone Management Act of 1972 (16
U.S.C. § 1451 et seq; TN1243) and the Farmland Protection
Policy Act of 1981 (7 U.S.C. §§ 4201 et seq.; TN708), if
applicable
Completed structures would not be sited within 1 mi of and
would not be visible from Federal or State parks or wilderness
areas, areas designated as Class I under Section 162 of the
Clean Air Act (42 U.S.C. § 7472-TN6954), or a Wild and
Scenic River or a National Heritage River, or a river of similar
State designation
No existing residential areas within 0.5 mi of site

The NRC staff recognizes that, without a detailed
consideration of specific land use conditions, as much
as 100 ac of land can be dedicated to a project within a
feasible setting without noticeably influencing the
availability of land for other purposes. The NRC staff
assumes any proposed project would meet NRC siting
regulations in 10 CFR Part 100 (TN282), or the
applicable NRC siting regulations in place at the time the
application is docketed. Establishing industrial facilities
close to residences can affect the use and enjoyment of
residents who desire home environments that are less
influenced by the sights, noise, odors, and other
parameters acceptable to industrial and commercial
workplace settings. A minimum distance of 0.5 mi
bounds a generic determination that potential conflicts
with residences would be SMALL, although a
consideration of specific site conditions could indicate
that closer distances could still be SMALL. An even
greater distance (1 mi) is needed to bound a generic
determination that a project would have only a SMALL
potential for adversely affecting features such as Federal
or State parks and conservation areas, whose qualities
are even more sensitive to industrial influences.

Table G-1
Parameter
Permanent Footprint
of Disturbance

G-3
Temporary Footprint of
Disturbance

Offsite rights-of-way
(ROW)

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

Values and Assumptions
30 ac of vegetated lands
Counts only land that supports vegetation as of project
baseline
3. No prime or unique farmland, or other farmland of statewide or
local importance (see Section 3.1.1 for definitions); or site
does not abut actively managed agricultural land and is not
situated in a predominantly agricultural landscape
4. No floodplains, surface water features, riparian habitat, latesuccessional vegetation, or dedicated conservation land
5. No more than 0.5 ac of wetlands in permanent or temporary
disturbance on the site or ROWs
6. The site and any existing ROWs do not have legacy
contamination requiring cleanup to protect human health or
the environment
7. No Individual Permits required under Section 404 of the Clean
Water Act (33 U.S.C. § 1344-TN1019)
8. Use of best management practices (BMPs) for soil erosion,
sediment control, and stormwater management
9. Implementation of mitigation specified in Clean Water Act
permits
10. Habitat is not known to be potentially suitable for one or more
Federal or State threatened or endangered species
1. Additional 20 ac of vegetated land
2. Counts only land that supports vegetation as of project
baseline
3. Meets assumptions for permanent footprint
4. Restored to original grade and seeded or planted with
indigenous vegetation once construction is complete
1.
2.

No longer than 1 mi and no wider than 100 ft, but allows for
unlimited additional mileage for linear features built within
existing ROWs or directly adjacent to existing ROWs or public
highways
Does not cause the total project-wide wetland fill to exceed
0.5 ac

Basis/Methodology
The total footprint of disturbance within areas of existing
vegetation (30 ac permanent plus an additional 20 ac of
temporary for a total of 50 ac) constitutes an estimate by
NRC staff of how much natural habitat excluding
unusually sensitive habitats can be disturbed, regardless
of geometric shape, in almost any landscape without
noticeably altering wildlife numbers or behavior. The
value of 0.5 ac of wetlands corresponds to the upper
ceiling for project-wide impacts on wetlands under many
Nationwide Permits (33 CFR Part 330; TN4318)
determined by the U.S. Army Corps of Engineers to
constitute minimal impact.

This additional temporary disturbance is factored
together with the assumption of no more than 30 ac
permanent disturbance into the overall disturbance area
of 50 ac (see above). Temporary disturbance of most
natural habitats followed by restoration constitutes less
impact per acre than permanent or long-term
disturbance. The limit of 0.5 ac of wetland impacts in
most Nationwide Permits (33 CFR Part 330; TN4318) is
a project-wide limit, inclusive of all associated permanent
and temporary impacts.
Dimensions of up to 1 mi long and 100 ft wide
constitutes an upper estimate by the NRC staff as to
how much new ROW can be established anywhere in
most rural landscapes without noticeably affecting
fragmented land uses or natural habitats, without
consideration of project-specific factors. The staff, based

Table G-1
Parameter

Values and Assumptions

Basis/Methodology

Would not involve ground disturbance to streams greater than
10 ft in width
4. Does not cross or pass within 1 mi of parks, wildlife refuges,
or conservation lands
5. Does not cross or pass within 1 mi of, or is not visible from,
Federal or State parks or wilderness areas, areas designated
as Class I under Section 162 of the Clean Air Act (42 U.S.C. §
7472-TN6954), or a Wild and Scenic River or a National
Heritage River, or a river of similar State designation
6. May span wetlands, waters of the United States, floodplains,
shoreline, or riparian lands
7. Any new transmission poles or towers would be constructed
outside of wetlands and floodplains
8. Pipelines or buried utilities would be directionally drilled under
surface waters to avoid physical disturbance of shorelines or
bottom substrates
9. Use of BMPs for soil erosion, sediment control, and
stormwater management
10. Implementation of mitigation specified in Clean Water Act
permits
11. No physical disturbance to streams greater than 10 ft in width
below the ordinary high-water mark
12. Access roads crossing non-jurisdictional surface water
features meet the substantive requirements of Nationwide
Permits 12 or 14 regarding limits on disturbance and
requirements for mitigation
1. 50 ft, except 200 ft for meteorological towers and 100 feet for
mechanical draft cooling towers
2. None of the structures would be built within or be visible from
Federal or State parks or wilderness areas, other areas
designated as Class I under Section 162 of the Clean Air Act
(42 U.S.C. § 7472-TN6954), or designated Wild and Scenic
Rivers
3. No transmission poles/towers over 100 ft

on its experience conducting environmental reviews,
concludes that co-location of new facilities within existing
ROWs or in new ROWs immediately adjacent to existing
ROWs or along existing roadways results in minimal
land use or ecological impacts. Such ROWs do not
fragment existing land uses or natural habitats or
introduce utility structures to settings previously lacking
such facilities. Additional assumptions address sensitive
facilities, which, if present, would necessitate a projectspecific analysis to assess the significance of impacts.
The limit of 0.5 ac of wetland impacts in most Nationwide
Permits (33 CFR Part 330; TN4318) is a project-wide
limit, inclusive of impacts from all project elements,
including offsite features.

G-4
Maximum Building and
Structure Height

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

Fifty feet constitutes a conservative estimate of building
heights that would not likely result in significant visual
intrusion or wildlife collision mortality in most settings.
This conclusion is based upon NRC reviews in past
reactor EISs. The staff recognizes that meteorological
towers must be taller to function, and that there would be
no need for more than one or two meteorological towers
per site. A transmission line with poles or towers taller
than 100 ft would be visible in a forested area and would
be highly visible in an open area. Most poles shorter
than 100 ft are not highly distinct visually from the
distribution poles for lower voltage electric lines that are

Table G-1
Parameter

Intake and Discharge

Values and Assumptions

1.
2.

G-5

In-Water Structures
(including intake and
discharge structures)

2.
3.

Cooling Towers

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

4.
1.
2.
3.

Adhere to the best available technology requirements of Clean
Water Act (CWA) 316(b) (33 U.S.C. § 1326-TN4823)
Operated in compliance with CWA Section 316 (b) and 40
CFR 125.83 (TN254), including compliance with monitoring
and recordkeeping requirements in 40 CFR 125.87 and 40
CFR 125.88, respectively
Best available technologies are employed in the design and
operation of intake and discharge structures to minimize
alterations due to scouring, sediment transport, increased
turbidity, and erosion
Adherence to requirements in National Pollutant Discharge
Elimination System (NPDES) permits issued by the U.S.
Environmental Protection Agency (EPA) or a given State
Constructed in compliance with provisions of the CWA Section
404 (33 U.S.C. § 1344-TN1019) and Section 10 of the Rivers
and Harbors Appropriation Act of 1899 (33 U.S.C. §§ 401 et
seq.; TN660)
Adverse effects of building activities controlled and localized
using BMPs such as installation of turbidity curtains or
installation of cofferdams
Any shorelines or other areas temporarily disturbed to build
intake and discharge structures would be restored using
regionally indigenous vegetation
Construction duration would be less than 7 years
No natural draft cooling towers
Would be equipped with drift eliminators
Makeup water would be fresh (salinity less than 1 ppt)

Basis/Methodology
common visual features in most settings. Mechanical
draft cooling towers are typically 50–100 ft in height
based on previous new nuclear reactor EIS analyses.
Requirements established in the subject regulations
have been developed to be protective of aquatic biota,
including protection of aquatic biota from excessive
impingement or entrainment.

Requirements of existing regulations related to in-water
construction are protective of aquatic resources and
have been found to keep the adverse impacts of building
activities localized and temporary.

Various past new nuclear reactor EISs indicate that
natural draft cooling towers are tall structures over 200 ft
in height that may be visible from substantial distances
and from which salt drift and fogging may affect
substantial areas of offsite land.

Table G-1

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

Parameter
Other Cooling Features 1.
2.
3.
4.

Values and Assumptions
No once-through cooling
No new cooling ponds
No new reservoirs
No spray irrigation ponds

Copper Alloy Tubes

No use of copper alloy tubes

Criteria Pollutant and
1.
Hazardous Air Pollutant
Emissions

G-6
Greenhouse Gas
Emissions

Criteria pollutants emitted from vehicles and standby power
equipment during construction and operations are less than
Clean Air Act de minimis levels set by the EPA if located in a
nonattainment or maintenance area
2. Hazardous Air Pollutant emissions will be within regulatory
limits
3. Construction and operation activities meet the permitting
requirements of applicable State and local agencies
4. Use of BMPs for dust control
New reactor construction and operation, including uranium fuel
cycle activities, transportation of fuel and waste, and
decommissioning will emit no more than 2,534,000 metric tonnes
(MT) CO2(e) for the lifespan of the project of 97 years

Basis/Methodology
Once-through cooling systems have a substantial
potential for significant impacts on aquatic biota from
entrainment and impingement and are essentially not
possible due to Section 316(b) of the Clean Water Act
(33 U.S.C. § 1326-TN4823). Operation of cooling ponds
can have potentially significant effects on aquatic and
terrestrial biota. Building reservoirs can affect large
areas of aquatic and terrestrial habitats, including
sensitive wetland, floodplain, and riparian habitats.
According to the License Renewal GEIS, copper alloy
tubes can introduce metal contaminants into discharged
blowdown water that can be harmful to aquatic biota.
Requirements of existing regulations related to air
emissions have been found to be protective of human
health and the environment.

Appendix H provides estimates of emissions of
greenhouse gases associated with building, operation,
fuel cycle, transportation of fuel and waste, and
decommissioning. Estimates of uranium fuel cycle
emissions are based on 5% enrichment.
1.
2.
3.
4.
5.

Construction equipment would emit 78,000 MT CO2(e)
during a 7-year construction period
Construction workforce would emit 86,000 MT CO2(e)
during a 7-year construction period
Plant operations would emit 362,000 MT CO2(e) during
a 40- year period
Plant workforce would emit 272,000 MT CO2(e) during
a 40- year period
The uranium fuel cycle would emit 1,620,000 MT
CO2(e) during a 40-year period. Transportation of Fuel

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Basis/Methodology

6.
7.
8.

Cooling-System Air
Quality

1.
2.

Hazardous Air Pollutant emissions will be within regulatory
limits
Subject to State permitting requirements

G-7
Ozone and Nitrogen
Transmission line voltage no higher than 1200 kilovolt(s)
Oxide (NOx) Emissions

Total Plant Water
Demand

1.
2.
3.

Municipal Water
Availability

Less than or equal to a daily average 6,000 gpm
The total plant water demand accounts for the maximum
amount of water supply required for all plant needs
The total plant water demand may include water from multiple
sources (e.g., surface water, groundwater, and/or municipal
water sources to meet certain water quality criteria)

The amount available from municipal water systems exceeds the
amount of municipal water required by the plant (gpm)
If municipal water is used for plant water supply:

and Waste would emit 42,000 MT CO2(e) during a 40year period
Decommissioning equipment would emit 38,000 MT
CO2(e) during a 10-year period
Decommissioning workforce would emit 16,000 MT
CO2(e) during a 10-year period
SAFe STORage workforce would emit 20,000 MT CO2
equivalent during a 40-year period

Previous new nuclear reactor reviews which have a
larger fuel cycle contribution based on Table S–3 have
concluded that the impact of the contribution of
greenhouse gases is SMALL.
The License Renewal GEIS (NRC 2024-TN10161) and
supplemental EISs for individual plant relicensing
evaluated the impact of continued operation of cooling
towers, including natural draft cooling towers, at existing
power plants for an additional 20 years and found the
impacts to be SMALL.
Impacts of existing transmission lines on air quality are
addressed in the License Renewal GEIS (NRC 2024TN10161) and Supplemental EISs for individual plant
relicensing, which have found impacts to be SMALL.
The License Renewal GEIS evaluated lines up to 1,200
kilovolts.
The NRC staff developed the total plant water demand
PPE by considering water requirements for all plant
systems from the set of currently known advanced
nuclear reactor designs considered by National Reactor
Innovation Center (2021-TN6940). The NRC staff
rounded this value up to the nearest 1,000 gpm to derive
the PPE.
Municipal water availability at a site is the amount of
excess capacity in the municipal systems that is
available after accounting for all existing and planned
future uses. The NRC staff can generically conclude that
the proposed project’s municipal water requirements
would not noticeably affect water resources at the site, if

Table G-1
Parameter

Values and Assumptions
1.
2.

Surface Water
Availability – Flowing
(Stream or River) (not
applicable if plant does
not use cooling water)

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

3.
4.

G-8

5.
6.
7.

Surface Water
1.
Availability – NonFlowing (not applicable if
plant does not use
2.
cooling water)
3.
4.

Basis/Methodology

Municipal Water Availability accounts for all existing and
planned future uses
An agreement or permit for the usage amount can be
obtained from the municipality

bounded by municipal water availability and the capacity
of the municipal systems.

The average rate of plant withdrawal does not exceed 3
percent of the 95 percent exceedance daily flow for the
waterbody (cubic feet per second)
Average plant water withdrawals do not reduce discharge
from the flowing waterbody by more than 3 percent of the
95 percent exceedance daily flow and do not prevent the
maintenance of applicable instream flow requirements
The 95 percent exceedance daily flow accounts for existing
and planned future withdrawals
Water availability is demonstrated by the ability to obtain a
withdrawal permit issued by State, regional or tribal governing
authorities
Water rights for the withdrawal amount are obtainable, if
needed
Changes in littoral zone water levels and hydroperiod resulting
from surface water withdrawals are within historical annual or
seasonal fluctuations
If withdrawals are from an estuary or intertidal zone, then
changes to salinity gradients are within the normal tidal or
seasonal movements that characterize the waterbody

The staff reviewed surface water withdrawals from and
related impacts on flowing waterbodies versus low-flow
metrics at the of currently operating and newly licensed
large light-water reactors (LWRs). In the reviews of
previous analyses, the staff found that water withdrawal
rates at or below 3 percent of the water available during
low flow conditions did not result in noticeable impacts.
Therefore, the NRC staff generically concluded that
plant surface water withdrawals that do not exceed 3
percent of the 95 percent exceedance daily flow in the
flowing waterbody used as the source, while accounting
for all existing and planned withdrawals, would not
noticeably affect surface water resources at the site.

Water availability of the Great Lakes, the Gulf of Mexico,
oceans, estuaries, and intertidal zones exceeds the amount of
water required by the plant
Water availability is demonstrated by the ability to obtain a
withdrawal permit issued by State, regional or tribal governing
authorities
Water rights for the withdrawal amount are obtainable, if
needed
Changes in littoral zone water levels and hydroperiod resulting
from surface water withdrawals are within historical annual or
seasonal fluctuations

Plant water withdrawal may alter salinity gradients in
flowing water bodies. The License Renewal GEIS (NRC
1996-TN288 and NRC 2024-TN10161) evaluated the
impact of plant withdrawals on altering salinity gradients
at operating plants and found the impacts to be SMALL
if they are localized and are within the normal tidal or
seasonal movements of salinity gradients that
characterize the waterbody.
The staff can generally conclude that the total plant
water demand of 6,000 gpm would not result in water
use conflicts in the Great Lakes, the Gulf of Mexico,
oceans, estuaries, and intertidal zones, because the
plant demand would be negligible as compared to water
availability. The staff acknowledges, however, that
smaller non-flowing surface waterbodies (e.g., inland
lakes, man-made ponds, and reservoirs) have limited
water availability. These waterbodies are not included in
the staff’s generic analysis.

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Municipal Systems’
1.
Available Capacity to
Receive and Treat Plant 2.
Effluent
3.

G-9

Groundwater Withdrawal 1.
for Plant Uses
2.
3.

4.
5.
6.

Groundwater Withdrawal 1.
for Excavation or
2.
Foundation Dewatering

If withdrawals are from an estuary or intertidal zone, then
changes to salinity gradients are within the normal tidal or
seasonal movements that characterize the waterbody
Coastal Zone Management Act of 1972 (16 U.S.C. §§ 1451 et
seq.; TN1243) consistency determination is obtainable, if
applicable

The available capacity of the municipal systems to treat
effluent exceeds the expected amount of plant effluent (gpm)
Municipal Systems’ Available Capacity to Receive and Treat
Plant Effluent accounts for all existing and planned future
discharges
Agreement to discharge to a municipal treatment system is
obtainable

Less than or equal to 50 gpm
Withdrawal results in no more than 1 ft of drawdown at the site
boundary
Withdrawals are not derived from an EPA-designated Sole
Source Aquifer, or from any aquifer designated by a State,
tribe, or regional authority to have special protections to limit
drawdown
Withdrawals meet the permitting requirements of applicable
State and local agencies
Changes in wetland water levels and hydroperiod resulting
from groundwater use are within historical annual or seasonal
fluctuations
Parameter value of 50 gpm is the total withdrawal for all plant
uses (excluding dewatering)

Dewatering rate less than or equal to 50 gpm
Dewatering results in negligible drawdown at the site
boundary

Basis/Methodology
Plant water withdrawal may alter salinity gradients in
non-flowing waterbodies. The License Renewal GEIS
(NRC 1996-TN288 and NRC 2024-TN10161) evaluated
the impact of plant withdrawals on altering salinity
gradients at operating plants and found the impacts to
be SMALL if they are localized and are within the normal
tidal or seasonal movements of salinity gradients that
characterize the waterbody.
Municipal systems’ available receiving and treatment
capacity is determined while accounting for all existing
and reasonably foreseeable future discharges. The NRC
staff can generically conclude that plant effluent treated
by a municipal system would not noticeably affect water
resources at the site, if bounded by the municipal
systems’ available capacity. The constituents present in
plant effluent are addressed in the municipal systems’
discharge permits.
This site parameter was based on the staff’s
determination in the License Renewal GEIS that ≤100
gpm groundwater withdrawal creates negligible or small
impacts at operating nuclear power plants because this
use rate would not generally lower groundwater levels
beyond the site boundary. The groundwater withdrawal
rate parameter was adjusted lower based on simplified
modeling showing that effects on groundwater levels at
the site boundary from pumping 50 gpm on a 100 ac site
would approximate the effects from pumping 100 gpm
on a larger site the size of a typical large LWR. The staff
assumed that groundwater withdrawals for plant uses
would result in less than a 1 ft reduction in groundwater
levels at the site boundary. The threshold of 1 ft was
selected as a de minimis value likely to be less than the
natural annual fluctuations in groundwater levels at most
sites.
The groundwater dewatering parameter was based on
the staff’s determination that impacts would be small if
dewatering would not lower groundwater levels beyond
the site boundary, which is consistent with the License

Table G-1
Parameter

Values and Assumptions
3.

4.
5.

Groundwater Quality

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

G-10

3.
4.
5.

Impacts on Aquatic Biota 1.
2.

Dewatering discharge has minimal effects on the quality of the
receiving waterbody (e.g., as demonstrated by conformance
with NPDES permit requirements)
Changes in wetland water levels and hydroperiod resulting
from dewatering are within historical annual or seasonal
fluctuations
Parameter value of 50 gpm represents the long-term
dewatering rate (the initial rate may be larger)

The plant is outside the recharge area for any EPAdesignated Sole Source Aquifer or any aquifer designated to
have special protections by a State, tribal, or regional authority
The plant is outside the wellhead protection area or
designated contributing area for any public water supply well
No planned plant discharges to the subsurface (by infiltration
or injection), including stormwater discharge
Applicable requirements and guidance on spill prevention and
control are followed, including relevant BMPs and Integrated
Pollution Prevention Plan
A groundwater protection program conforming to NEI 07-07
(NEI 2019-TN6775) is established and followed
Adherence to regulatory limits in 40 CFR 125.84 (TN254)
Adherence to requirements in NPDES permits issued by the
EPA or a given State

Radiological
For protection against radiation, the applicant must meet the
Environmental Hazards regulatory requirements of:
•
•
•
•

10 CFR 20.1101 Radiation Protection Programs (10 CFR Part
20-TN283) if issued a license
10 CFR 20.1201 Occupational dose limits for adults
10 CFR 20.1301 Dose limits for individual members of the
public
Appendix B of 10 CFR Part 20 Annual Limits on Intake (ALIs)
and Derived Air Concentrations (DACs) of Radionuclides for

Basis/Methodology
Renewal GEIS. Based on simplified modeling, the staff
determined that, relative to the plant site area, the
effects on groundwater levels caused by dewatering
withdrawals of 50 gpm at a 100 ac site would be similar
to the effects caused by dewatering withdrawals of
100 gpm on a larger site the size of a typical large LWR.
Consistent with the site area for the new nuclear reactor,
the staff assumed in this simplified modeling that the
area to be dewatered and the depth of groundwater
drawdown at the excavation/foundation would be smaller
than for a typical large LWR.
Because groundwater quality degradation would have
the greatest effects on other users of the resource when
groundwater at the plant site contributes to the source
water for other users, the potential impacts on
groundwater quality from plant construction and
operation will be minimized when the plant is located
outside the recharge areas for critical groundwater
supplies and when there are no planned discharges to
the subsurface. In addition, spill prevention/control
requirements and a groundwater protection program
help prevent releases of contaminants to groundwater
and to minimize the impacts of any releases that
inadvertently occur.
Requirements of existing regulations related to aquatic
biota impacts are protective of aquatic resources and
have been found to keep adverse impacts localized and
temporary.
Requirements of existing regulations related to
radiological health have been found to be protective of
workers and members of the public and are minimized
through a radiation protection program that implements
ALARA (as low as is reasonably achievable).

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

•
•

Basis/Methodology

Occupational Exposure; Effluent Concentrations;
Concentrations for Release to Sewerage
10 CFR 50.34a (10 CFR Part 50-TN249) Design objectives for
equipment to control releases of radioactive material in
effluents—nuclear power reactors
10 CFR 50.36a Technical specifications on effluents from
nuclear power reactors

Applicants would demonstrate in their application that any
radiological nonhuman biota doses would be below IAEA (1992TN712) and National Council on Radiation Protection and
Measurements (NCRP) (1991-TN729) guidelines
Application contains sufficient technical information for the staff to
complete the detailed technical safety review

G-11

Application will be found to be in compliance by the staff with the
above regulations through a radiation protection program and an
effluent release monitoring program
Nonradiological
1.
Environmental Hazards
2.

The applicant must adhere to all applicable Federal, State,
local, or tribal regulatory limits and permit conditions for
chemical hazards, biological hazards, and physical hazards
from a proposed advanced reactor
The applicant will follow nonradiological public and
occupational health BMPs and mitigation measures, as
appropriate, to govern building and operations-related
activities

Wildlife-Related Noise
Generation

85 decibel(s) on the A-weighted scale (dBA) 50 ft from the source

Human-Related Noise
Generation

65 dBA at site boundary, unless a relevant State or local noise
abatement law or ordinance sets a different threshold, which
would then be the presumptive threshold for PPE purposes.
If an applicant cannot meet the 65 dBA threshold through
mitigation, then the applicant must obtain a various or
exception with the relevant State or local regulator.

Requirements of existing regulations related to
nonradiological environmental hazards are protective of
human health and have been found to keep the adverse
impacts of building and operations-related activities
localized and temporary.

NRC staff has historically relied upon the Federal
Highway Administration Construction Noise Handbook
(WSDOT 2017-TN5313) to determine that a noise level
of 85 dBA 50 ft from the source is typical.
The License Renewal GEIS (NUREG-1437; NRC 2024TN10161) determined that noise levels are considered
acceptable if the day-night average sound level outside
a residence is less than 65 dBA. This limit is also
included in the NRC Environmental Standard Review
Plans (NUREG-1555; NRC 2000-TN614).

Table G-1
Parameter

Values and Assumptions
3.

Radiological Waste
Management

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Basis/Methodology

Project will implement BMPs, including such as modeling,
foliage planting, construction of noise buffers, and the timing
of construction and/or operation activities.

Applicants must meet the regulatory requirements of 10 CFR Part
20 (TN283) (e.g., 20.1406 and Subpart K), 10 CFR Part 61
(TN252), 10 CFR Part 71 (TN301), and 10 CFR Part 72 (TN4884)

Requirements of existing regulations related to
radiological waste management have been found to be
protective of human health and the environment.

LLRWs at existing nuclear power plants generate an average of
21,200 ft3 (600 m3) and 2,000 Ci (7.4 × 1013 Bq) per year for
boiling water reactors and half that amount for pressurized water
reactors (NRC 2024-TN10161)

G-12

Nonradiological Waste
Management

Postulated Accidents

Resource Conservation and Recovery Act (RCRA) Small Quantity
Generator (EPA 2020-TN6590) for Mixed Waste
1. Applicants must meet all applicable permit conditions,
regulations, and BMPs related to solid, liquid, and gaseous
waste management
2. For hazardous waste generation, applicants must meet the
conformity with the appropriate hazardous waste quantity
generation level in accordance with RCRA (EPA 2020TN6590)
3. For sanitary waste, applicants must treat sanitary waste in a
permitted process
4. Perform mitigation measures, to the extent practicable, such
as recycling, process improvements, or using a less
hazardous substance
For design basis accidents,1 the exclusion area boundary
maximum total effective dose equivalent for any 2-hour period and
the low-population zone maximum total effective dose equivalent
for the duration of the accident release

Requirements of existing regulations and applicable
permits related to nonradiological waste management
have been found to be protective of human health and
the environment and have been found to keep the
adverse impacts of building and operation activities
localized and temporary.

Requirements of existing regulations related to
postulated accidents are protective of human health.
The applicant would have to demonstrate meeting the
dose requirements contained in 10 CFR 50.34(a)(1)

For the purposes of this GEIS, “Design Basis Accidents” are related to a spectrum of accidents that will be evaluated for satisfying siting requirements (e.g., 10
CFR Part 100-TN282) and the safety analysis requirements (e.g., 10 CFR Part 50-TN249, 10 CFR Part 52-TN251) or the applicable NRC safety and siting
regulations in place at the time the application is docketed).

Table G-1

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)

Parameter

Values and Assumptions
For accidents involving releases of hazardous chemicals:
•
•

New reactor inventory of a regulated substance is less
than its Threshold Quantity (TQ). TQs are found in 40
CFR 68.130, Tables 1, 2, 3, and 4 (TN5494); and
New reactor inventory of an EHS is less than its
Threshold Planning Quantity (TPQ). TPQs are found in 40
CFR Part 355, Appendices A and B (TN5493).

A cost-screening analysis determines that the maximum benefit for
avoiding an accident is so small that a severe accident
mitigation alternative (SAMDA) analysis is not justified
based on a minimum cost to design an appropriate SAMDA.
The proposed site is not within the jurisdiction of the United States
Court of Appeals for the Ninth Circuit

G-13
Site Employment

Peak project-related in-migrating workforce including families does
not exceed established local planning and growth projections for
infrastructure and service demands

Basis/Methodology
(TN249) Design objectives for equipment to control
releases of radioactive material in effluents – nuclear
power reactors, or 10 CFR 52.17(a)(1) (TN251),
Contents of applications; technical information, or 10
CFR 52.79(a)(1)(A), Contents of applications; technical
information in Final Safety Analysis Report, as
applicable.
For hazardous chemical accidents, the applicant would
make a comparison of hazardous chemical inventories
to the TQs found in 40 CFR 68.130, Tables 1, 2, 3, and
4 (TN5494); and the TPQs in 40 CFR Part 355,
Appendices A and B (TN5493).
For SAMDAs, the staff expects that the safety analysis
would have core damage frequencies (CDFs) that would
likely be substantially less than CDFs associated with
the current reactor fleet. For non-LWR severe accident
mitigation alternative screening and assessments, event
or release category frequency could be used in place of
CDFs. In such cases a cost screening could determine
that the maximum benefit for avoiding an accident is so
small that a SAMDA is not justified based on a minimum
cost to design an appropriate SAMDA. This costscreening process would be based on the available risk
information from the safety analysis report and apply the
cost formulas from NUREG/BR-0058 (NRC 2020TN6806).
Acts of terrorism: If within the jurisdiction of the United
States Court of Appeals for the Ninth Circuit, appropriate
staff analysis would be performed based in part on the
physical protection requirements under 10 CFR Part 73
(TN423).
Some construction and operations workers and their
families are assumed to relocate to the economic region of
the proposed project. Staff assumes growth planning for
the affected infrastructure and services would factor these

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Community Services
1.
and Infrastructure (e.g.,
housing availability;
school capacities)
2.

the housing vacancy rate in the affected economic region
remains at least 5 percent of the housing stock after removing
sufficient rental units to accommodate the in-migrating
construction workers,
student:teacher ratios in the affected economic region do not
decline below the locally mandated levels after including the
school age children of the in-migrating construction worker
families housing and education resources would be the only
resource areas where noticeable impacts might occur

G-14

Transportation Systems Level of service (LOS) determination for affected roadways does
and Traffic
not change

Fuel Cycle

Table S–3 bounds the impacts for the proposed reactor, because
of uranium fuel cycle changes since WASH-1248 (AEC 1974TN23), including:
• Increasing use of in situ leach uranium mining
• Transitioning of U.S. uranium enrichment technology from
gaseous diffusion to gas centrifugation.
• Current LWRs are using nuclear fuel more efficiently due
to higher levels of fuel burnup
• Less reliance on coal-fired electrical generation plants
Reprocessing capacity up to 900 metric tonnes uranium/year
(MTU/yr)

Basis/Methodology
changes into baseline service demand projections. This
assumption is based on staff experience since 2005 for
more than 20 license application reviews. Peak projectrelated workforce increases are assumed to cause
minimal effects on most services and infrastructure as
long as increases are within local government planning
projections.
This assumption is based on staff experience since 2005
with more than 20 license application reviews. Staff
experience indicates a healthy housing market maintains
a vacancy rate of five percent of the total housing stock,
and any local, regional, or State mandated threshold
(e.g., a student:teacher ratio) establishes the point of
inflection from a SMALL impact to a MODERATE
impact.
Movement between LOS classes (A, B, C, D, E, F)
would be noticeable to drivers. Increased traffic that
does not trigger a movement between these classes
would be a minor impact. This assumption is based on
the industry-standard LOS approach that has been used
in previous NRC NEPA assessments since 2005.
Advances in the uranium fuel cycle (as noted in the
values and assumptions columns) have reduced the
various impacts of the fuel cycle from what is presented
in Table S–3. For example, higher burnup levels allow
for longer periods of time between refueling thus
reducing the annual number of fuel assemblies
discharged from a reactor.
Requirements of existing regulations related to the safe
processing, storage, transportation, and security of
nuclear material have been found to be protective of
workers and members of the public.

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Uranium fuel cycle impacts will bound the thorium fuel cycle
impacts

Basis/Methodology
Fuel fabrication impacts for metal fuel and liquid fueled
molten salt are not included in the staff’s generic
analysis.

Waste and spent fuel inventories, as well as their associated
certified spent fuel shipping and storage containers, are not
significantly different from what has been considered for LWR
evaluations in NUREG-2157 (NRC 2014-TN4117)

G-15

Must satisfy the regulatory requirements of 10 CFR Part 40
(TN4882) Domestic Licensing of Source Material, 10 CFR
Part 50 (TN249) Domestic Licensing of Production and
Utilization Facilities, 10 CFR Part 70 (TN4883), Domestic
Licensing of Special Nuclear Material, 10 CFR Part 71
(TN301), Packaging and Transportation of Radioactive
Material, 10 CFR Part 72 (TN4884), Licensing Requirements
for the Independent Storage of Spent Fuel, High-Level
Radioactive Waste, and Reactor-related Greater Than Class
C Waste, and 10 CFR Part 73 (TN423), Physical Protection of
Plants and Materials.
Transportation of
Unirradiated Fuel

Consistency with thresholds for the maximum shipment distances
in Tables 3.15-2 and 3.15-3, 59,160 km and 118,320 km
respectively.
The shipments are normalized to a net electrical output of 880
MW(e), i.e., 1,100 MW(e) with an 80 percent capacity factor from
WASH-1238 (AEC 1972-TN22)
The parameter does not apply to situations where a new nuclear
reactor applicant proposes shipping the unirradiated fuel by air,
ship or barge; or where an applicant proposes that an unirradiated
fuel transportation package be approved using the provisions of 10
CFR 71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d) (10 CFR Part
71-TN301)

Accident frequencies for transportation of unirradiated
fuel are expected to be lower than those used in the
analysis in WASH-1238 (AEC 1972-TN22). This is
based on the NRC staff review of the trends in
improvements in highway safety and security, and an
overall reduction in traffic accident, injury, and fatality
rates since WASH-1238 was published. Although
packages for all types of unirradiated fuel have not been
designed or certified by the NRC, these packages must
comply with the packaging requirements contained in 10
CFR Part 71 (TN301) and for this reason, the impacts of
radiological accidents during transport of unirradiated
fuel are expected to be smaller than those listed in Table
S-4 in 10 CFR 51.52 (TN250).
The PPE applies to situations where the enrichment of
the unirradiated fuel is 20 percent or less, based on the
unlimited A2 value in Table A-1 in 10 CFR Part 71 for

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Basis/Methodology
unirradiated uranium enriched to 20 percent or less (10
CFR Part 71-TN301).

Transportation of
Radioactive Waste

Consistency with thresholds for the maximum shipment distance in
Table 3-16, 293,145 km.
The shipments are normalized to a net electrical output of 880
megawatt(s) electrical (MWe,) i.e., 1,100 MWe with an 80 percent
capacity factor and a shipment volume of 2.34 m3/shipment from
WASH-1238 (AEC 1972-TN22).

G-16

Transportation of
Irradiated Fuel

This PPE does not apply to situations where a new nuclear reactor
applicant proposes shipping the radioactive waste by air, ship or
barge; or where an applicant proposes that a radioactive waste
transportation package be approved using the provisions of 10
CFR 71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d) (10 CFR Part
71-TN301)
Consistency with the thresholds for the maximum shipment
distances, and burnup included in Tables 3.15-8 through 3.15-10,
505,393 km and 1,010,786 km.
The shipments are normalized to a net electrical output of 880
MWe, i.e., 1,100 MWe with an 80 percent capacity factor and a
shipment capacity of 0.5 MTU/shipment from WASH-1238 (AEC
1972-TN22)
This PPE is based on a maximum peak rod burnup of
62 GWd/MTU for uranium oxide fuel and 133 GWd/MTU for TRistructural ISOtropic fuel
This PPE does not apply to situations where a new nuclear reactor
applicant proposes shipping the irradiated fuel by air, ship or
barge; or where a new nuclear reactor applicant proposes that an
irradiated fuel transportation package be approved using the
provisions of 10 CFR 71.12, 10 CFR 71.41(c), or 10 CFR 71.41(d)
(10 CFR Part 71-TN301) such as might be applied for when
shipping a complete irradiated reactor core

Reviewed impacts from previous LWR early site permit
(ESP) and combined license (COL) environmental
analyses, which have concluded that the impacts of
transportation of radioactive waste were SMALL.

Reviewed impacts from previous LWR ESP and COL
environmental analyses, which have concluded that the
impacts of transportation of irradiated fuel were SMALL.

Table G-1
Parameter

Decommissioning

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

G-17

In addition, the irradiated fuel must be shipped in a transportation
package that meets all of the applicable NRC regulations
The environmental impacts for the following resource areas were
generically addressed in NUREG-0586, Supplement 1, would be
limited to operational areas, would not be detectable or
destabilizing and are expected to have a negligible effect on the
impacts of terminating operations and decommissioning:
• Onsite land use
• Water use
• Water quality
• Air quality
• Aquatic ecology within the operational area
• Terrestrial ecology within the operational area
• Radiological
• Radiological accidents (non-spent-fuel-related)
• Occupational issues
• Socioeconomic
• Onsite cultural and historic resources for plants where the
disturbance of lands beyond the operational areas is not
anticipated
• Aesthetics
• Noise
• Transportation
• Irretrievable resource
The following issues were not addressed in NUREG-0586,
Supplement 1, but have been determined to be Category 1 issues:
• Nonradiological waste
• Greenhouse gases
The following two issues were identified in NUREG-0586,
Supplement 1, as requiring a project-specific review:
• Environmental justice
• Threatened and endangered species

Basis/Methodology

NUREG-0586 Supplement 1 Decommissioning GEIS
(NRC 2002-TN665)
Requirements of existing regulations related to
decommissioning activities have been found to be
protective of workers, members of the public, and the
environment.

Table G-1
Parameter

Plant Parameter Envelope and Site Parameter Envelope for New Reactors (Continued)
Values and Assumptions

Basis/Methodology

Four conditionally project-specific issues identified in NUREG0586, Supplement 1, will require a project-specific review if
present:
• Land use involving offsite areas to support
decommissioning activities
• Aquatic ecology for activities beyond the licensed
operational area
• Terrestrial ecology for activities beyond the licensed
operational area
• Historic and cultural resources (archaeological,
architectural, structural, historic) for activities within and
beyond the licensed operational area with no current (i.e.,
at the time of decommissioning) evaluation of resources
for NRHP eligibility

G-18

Additionally, the following two environmental resource areas are
additional decommissioning impacts that require project-specific
review:
• Climate change: the effects of climate change are
location-specific and cannot, therefore, be evaluated
generically (see Section 1.3.3.2.2, Category 2 Issues
Applying Across Resources, of this NR GEIS)
Cumulative effects: must be considered on a project-specific basis
where impacts would depend on regional resource characteristics,
the resource specific impacts of the project, and the cumulative
significance of other factors affecting the resource. (see Section
1.3.3.2.2, Category 2 Issues Applying Across Resources, of this
NR GEIS)
Operational Life of the
Plant
Construction Phase of
the Plant

40-year operational life, assuming a 40-year license

10 CFR 50.51(a) (TN249) and 52.104 (TN251).

7-year construction life to complete construction activities

Based off previous new nuclear reactor EIS reviews.

G.1

References

2
3

10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, “Standards for
Protection Against Radiation.” TN283.

4
5

10 CFR Part 40. Code of Federal Regulations, Title 10, Energy, Part 40, “Domestic Licensing of
Source Material.” TN4882.

6
7

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of
Production and Utilization Facilities.” TN249.

8
9

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental
Protection Regulations for Domestic Licensing and Related Regulatory Functions.” TN250.

10
11

10 CFR Part 52. Code of Federal Regulations, Title 10, Energy, Part 52, “Licenses,
Certifications, and Approvals for Nuclear Power Plants.” TN251.

12
13

10 CFR Part 61. Code of Federal Regulations, Title 10, Energy, Part 61, “Licensing
Requirements for Land Disposal of Radioactive Waste.” TN252.

14
15

10 CFR Part 70. Code of Federal Regulations, Title 10, Energy, Part 70, “Domestic Licensing of
Special Nuclear Material.” TN4883.

16
17

10 CFR Part 71. Code of Federal Regulations, Title 10, Energy, Part 71, “Packaging and
Transportation of Radioactive Material.” TN301.

18
19
20

21
22

10 CFR Part 73. Code of Federal Regulations, Title 10, Energy, Part 73, “Physical Protection of
Plants and Materials.” TN423.

23
24

10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, “Reactor Site
Criteria.” TN282.

25
26

33 CFR Part 330. Code of Federal Regulations, Title 33, Navigation and Navigable Waters, Part
330, “Nationwide Permit Program.” TN4318.

27
28

40 CFR Part 68. Code of Federal Regulations, Title 40, Protection of Environment, Part 68,
“Chemical Accident Prevention Provisions.” TN5494.

29
30
31

40 CFR Part 125. Code of Federal Regulations, Title 40, Protection of Environment, Part 125,
“Criteria and Standards for the National Pollutant Discharge Elimination System.” Washington,
D.C. TN254.

32
33

40 CFR Part 355. Code of Federal Regulations, Title 40, Protection of Environment, Part 302,
“Emergency Planning and Notification.” TN5493.

34
35

33 U.S.C. § 1326. U.S. Code Title 33, Navigation and Navigable Waters, Section 1326,
“Thermal Discharges.” TN4823.
G-19

1
2
3

42 U.S.C. § 7472. Clean Air Act Section 162, “Initial Classifications.” TN6954.

5
6
7

8
9

AEC (U.S. Atomic Energy Commission). 1974. Environmental Survey of the Uranium Fuel
Cycle. WASH–1248, Washington, D.C. ADAMS Accession No. ML14092A628. TN23.

Coastal Zone Management Act of 1972. 16 U.S.C. § 1451 et seq. TN1243.

11
12

EPA (U.S. Environmental Protection Agency). 2020. “Categories of Hazardous Waste
Generators.” Washington, D.C. ADAMS Accession No. ML21141A344. TN6590.

Farmland Protection Policy Act of 1981. 7 U.S.C. § 4201 et seq. TN708.

14
15
16

17
18

NCRP (National Council on Radiation Protection and Measurements). 1991. Effects of Ionizing
Radiation on Aquatic Organisms. NCRP Report No. 109, Bethesda, Maryland. TN729.

19
20
21

NEI (Nuclear Energy Institute). 2019. Industry Groundwater Protection Initiative – Final
Guidance Document, Rev. 1. NEI-07-07, Revision 1, Washington, D.C. ADAMS Accession No.
ML19142A071. TN6775.

22
23
24

NRC (U.S. Nuclear Regulatory Commission). 1996. Generic Environmental Impact Statement
for License Renewal of Nuclear Plants. Volumes 1 and 2, NUREG–1437, Washington, D.C.
ADAMS Accession Nos. ML040690705, ML040690738. TN288.

25
26
27
28

NRC (U.S. Nuclear Regulatory Commission). 2000. Environmental Standard Review Plan—
Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG–1555,
Main Report and 2007 Revisions, Washington, D.C. Available at http://www.nrc.gov/readingrm/doc-collections/nuregs/staff/sr1555/toc/. TN614.

29
30
31
32

NRC (U.S. Nuclear Regulatory Commission). 2002. Final GEIS of Decommissioning of Nuclear
Facilities: Regarding the Decommissioning of Nuclear Power Reactors. NUREG–0586,
Supplement 1, Volumes 1 and 2, Washington, D.C. ADAMS Accession Nos. ML023470327,
ML023500228. TN665.

33
34
35

NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement
for License Renewal of Nuclear Plants [GEIS]. NUREG–1437, Revision 1, Washington, D.C.
ADAMS Package Accession No. ML13107A023. TN2654.

G-20

1
2
3

4
5
6

NRC (U.S. Nuclear Regulatory Commission). 2020. Policy Issue: Draft Final NUREG/BR-0058,
Revision 5, “Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission.”
SECY-20-0008, Washington, D.C. ADAMS Pkg. Accession No. ML19261A277. TN6806.

7
8
9

NRIC (National Reactor Innovation Center). 2021. Advanced Nuclear Reactor Plant Parameter
Envelope and Guidance. NRIC-21-ENG-0001, Washington, D.C. ADAMS Accession No.
ML21145A416. TN6940.

Rivers and Harbors Appropriation Act of 1899. 33 U.S.C. § 401 et seq. TN660.

11
12
13
14
15

G-21

APPENDIX H

1
2
3
4

GREENHOUSE GAS EMISSIONS ESTIMATES FOR A REFERENCE
1,000 MWE REACTOR

5
6
7
8
9
10
11
12
13

The U.S. Nuclear Regulatory Commission (NRC) staff estimated the greenhouse gas (GHG)
emissions of various activities associated with the building, operation, and decommissioning of
nuclear power plants. The GHG emission estimates include direct emissions from the nuclear
facility and indirect emissions from workforce and fuel transportation, decommissioning, and the
uranium fuel cycle. The estimates are based on a single installation of 1,000 megawatt(s)
electrical (MWe) output with an 80 percent capacity factor henceforth referred to as the
reference 1,000 MWe reactor. The estimates may be roughly linearly scaled from the reference
1,000 MWe reactor for other reactor outputs1 This appendix discusses the calculation of GHG
emission estimates for the reference 1,000 MWe reactor.

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

The estimated emissions from equipment used to build a nuclear power plant listed in Table H-1
are based on hours of equipment use estimated for a single nuclear power plant at a site
requiring a moderate amount of terrain modification (UniStar 2007-TN1564). Construction
equipment carbon monoxide (CO) emission estimates were derived from the hours of
equipment use, and carbon dioxide (CO 2) emissions were then estimated from the CO
emissions using a scaling factor of 172 tons of CO2 per ton of CO (Chapman et al. 2012TN2644). The scaling factor is based on the ratio of CO 2 to CO emission factors for diesel fuel
industrial engines as reported in Table 3.3-1 of AP-42 Compilation of Air Pollutant Emission
Factors (EPA 2012-TN2647). A CO2 to total GHG equivalency factor of 0.991 is used to account
for the emissions from other GHGs, such as methane (CH 4) and nitrous oxide (N2O) (Chapman
et al. 2012-TN2644). The equivalency factor is based on non-road/construction equipment in
accordance with relevant guidance (NRC 2014-TN3768; Chapman et al. 2012-TN2644).
Equipment emissions estimates for decommissioning are assumed to be one-half of those for
construction equipment. Data on equipment emissions for decommissioning are not available;
the one-half factor is based on the assumption that decommissioning would involve less
earthmoving and hauling of material, as well as fewer labor hours, compared to those involved
in building activities (Chapman et al. 2012-TN2644).

31
32
33
34
35
36
37
38
39
40

Table H-2 lists the NRC staff’s estimates of the CO 2(e)2 emissions associated with workforce
transportation. Construction workforce estimates for the reference 1,000 MWe reactor are
conservatively based on estimates in various combined license (COL) applications (Chapman
et al. 2012-TN2644), and the operational and decommissioning workforce estimates are based
on Supplement 1 to NUREG–0586 (NRC 2002-TN665). Table H-2 lists the assumptions used to
estimate total miles traveled by each workforce and the factors used to convert total miles to
metric tons of CO2(e). The workers are assumed to travel in gasoline-powered passenger
vehicles (cars, trucks, vans, and sport utility vehicles) that get an average of 21.6 mi/gal of
gasoline (FHWA 2012-TN2645). Conversion from gallons of gasoline burned to CO 2(e) is based
on U.S. Environmental Protection Agency (EPA) emission factors (EPA 2012-TN2643).
The term “model LWR” has also been used to describe a 1,000 MWe light water reactor for the purpose of
evaluating the environmental considerations of the supporting fuel cycle to the annual reactor operations (WASH1248, AEC 1974-TN23). It is assumed there are no significant differences between the 1,000 MWe reactor evaluated
in WASH-1248 and the 1,000 MWe reference reactor evaluated in this appendix.
1

A measure to compare the emissions from various GHGs on the basis of their global warming potential
(GWP), defined as the ratio of heat trapped by one unit mass of the GHG to that of one unit mass of CO 2
over a specific time period.

H-1

1
2

Table H-1

Green House Gas Emissions from Equipment Used in Building
and Decommissioning (metric tonnes [MT] CO2(e))
Building Total(a)
12,000
3,400
5,400
5,600
1,000
1,400
10,000
39,000

Equipment
Earthwork and dewatering
Batch plant operations
Concrete
Lifting and rigging
Shop fabrication
Warehouse operations
Equipment maintenance
Total(c)

Decommissioning Total(b)
6,000
1,700
2,700
2,800
500
700
5,000
19,000

(a) Based on hours of equipment usage over a 7-year period.
(b) Based on equipment usage over a 10-year period.
(c) Results are rounded to the nearest 1,000 MT CO2 equivalent (CO2(e)).

Table H-2

Commuting Trips
(round trips per day)
Commute Distance
(miles per round-trip)
Commuting Days
(days per year)
Duration
(years)
Total Distance Traveled
(miles)(a)
Average Vehicle Fuel
Efficiency(b)
(miles per gallon)
Total Fuel Burned(a)
(gallons)
CO2 Emitted Per Gallon(c)
(MT CO2)
Total CO2 Emitted(a)
(MT CO2)
CO2 Equivalency Factor(c)
(MT CO2/MT CO2(e))
Total GHG Emitted(a)
(MT CO2(e))

Workforce Green House Gas Footprint Estimates
Construction
Workforce
1,000

Operational
Workforce
550

Decommissioning
Workforce
200

SAFe
STORage
Workforce
40

365

250

365

102,000,000

321,000,000

20,000,000

23,000,000

21.6

4,700,000

14,900,000

900,000

1,100,000

0.00892

42,000

133,000

8,000

10,000

0.977

43,000

136,000

8,000

10,000

(a) Results are rounded.
(b) Source: FHWA 2012-TN2645.
(c) Source: EPA 2012-TN2643.

H-2

1
2
3
4
5
6
7
8
9

Title 10 of the Code of Federal Regulations 51.51(a) (10 CFR 51.51(a); TN250) states that
every environmental report3 prepared for an early site permit or COL stage of a light-watercooled nuclear power reactor shall use Table S–3, Table of Uranium Fuel Cycle Environmental
Data, as set forth in 10 CFR 51.51(b) (TN250) as the basis for evaluating the contribution of the
environmental effects of uranium fuel-cycle activities to the environmental costs of licensing the
nuclear power reactor. Section 51.51(a) (TN250) further states that Table S–3 shall be included
in the environmental report and may be supplemented by a discussion of the environmental
significance of the data set forth in the table as weighted in the project-specific analysis for the
proposed facility.

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33

Table S–3 of 10 CFR 51.51(b) (TN250) does not directly apply to non-light-water reactors
(LWRs), nor does it provide an estimate of GHG emissions associated with the uranium fuel
cycle; it only addresses pollutants that were of concern when the table was promulgated in the
1970s. However, Table S–3 states that 323,000 MWh is the assumed annual electric energy
use for the Table S–3 reference 1,000 MWe nuclear power plant and that this 323,000 MWh of
annual electric energy is assumed to be generated by a 45 MWe coal-fired power plant burning
118,000 MT of coal. These assumptions are based upon 1970s uranium enrichment technology,
which has changed substantially since then. The older, energy-intensive gaseous-diffusion
plants have been replaced with more efficient centrifuge-based systems. The current operating
gas centrifuge uranium enrichment facility in the United States is URENCO-USA (Louisiana
Energy Services), which is located in Eunice, New Mexico. The URENCO-USA facility does not
rely solely upon coal as an energy source (Napier 2020-TN6443). If a 1,000 MWe plant is
assumed to operate at 35 percent thermal efficiency and use uranium fuel enriched to 5 percent
in uranium-235 (U-235) with an average burnup of 40,000 megawatt-day/metric tonnes
(MWd/MT) for 40 years, then it will require about 1,043 tons of enriched uranium for fuel. To
produce 1 ton of 5 percent enriched uranium with 0.25 percent U-235 in the depleted uranium
stream requires extraction of 10.3 tons of natural uranium and 7,923 separative work units, or
SWUs (Napier 2020-TN6443). The 1,043 tons of uranium enriched to 5 percent U-235 required
over the 40-year life of the 1,000 MWe plant would then require 8,264,000 SWUs. Because a
centrifuge enrichment facility requires about 50 kWh per SWU (WNA 2020-TN6661), a total of
413,200 MWh is needed to produce 40 years’ worth of uranium enriched to 5 percent U-235 for
fuel for the lifetime operation of the 1,000 MWe plant. For the existing U.S. centrifuge
enrichment plant, the regional average CO 2 emission factor is 1,248 lb/MWh,4 and the total CO2
emission is about 243,000 MT.

34
35
36
37
38
39
40

Table S–3 also assumes that approximately 135,000,000 standard cubic feet of natural gas is
required per year to generate process heat for certain portions of the uranium fuel cycle. The
NRC staff estimates that burning 135,000,000 standard cubic feet of natural gas per year results
in approximately 7,440 MT of CO2(e) being emitted into the atmosphere per year because of the
process heat requirements of the uranium fuel cycle.5 For a 40-year operational life, this is
298,000 MT of CO2(e). This amount is in addition to the CO 2(e) emissions from the enrichment
process.

The NRC requires most applicants, including all reactor applicants, to submit an environmental report as part of the
application. 10 CFR 51.45 and 10 CFR 51.50 (10 CFR Part 51-TN250).
4
The EPA provides estimates of emissions from electricity production for different regions in the United States at
https://www.epa.gov/energy/emissions-generation-resource-integrated-database-egrid for CO2 in units of pounds per
kilowatt-hour (lb/kWh). The value for southeastern New Mexico has been applied here.
5
The conversion is 0.0551 (metric tons CO2/thousand standard cubic feet (https://www.epa.gov/energy/greenhousegases-equivalencies-calculator-calculations-and-references).

H-3

1
2
3
4
5
6
7
8

The NRC staff estimated GHG emissions related to plant operations from the typical usage of
various onsite diesel generators (UniStar 2007-TN1564). CO emission estimates were derived
assuming an average of 600 hours of emergency diesel generator operation per year (four
generators, each operating 150 hr/yr) and 200 hours of station blackout diesel generator
operation per year (two generators, each operating 100 hr/yr) (Chapman et al. 2012-TN2644). A
scaling factor of 172 was then applied to convert the CO emissions to CO 2 emissions, and a
CO2 to total GHG equivalency factor of 0.991 was used to account for the emissions from other
GHGs such CH4 and N2O (Chapman et al. 2012-TN2644).

9
10
11
12
13
14
15
16
17

The number of shipments and shipping distances for transport of fresh nuclear fuel to and spent
nuclear fuel and radioactive wastes are presented in Table S-5 of Supplement 1 to WASH-1238
[NRC 1975-TN216], for a 1,100 MWe LWR with an 80 percent capacity factor. WASH-1248
(AEC 1974-TN23) assumes that truck casks weigh 50,000 lb (23 MT) and rail casks weigh
100 T (91 MT). For this analysis, emission rates of CO 2 for trucks are taken to be 64.7 g/T-mi
(44.2 g/MT-km) and for rail are taken to be 32.2 g/T-mi (22 g/MT-km) (Cefic and ECTA 2011TN6966). For the calculation, it is also assumed that return trips with empty casks double the
total miles traveled by truck or rail. Table H-3 presents estimated annual CO2e emissions from
shipments associated with the reference 1,000 MWe reactor.

Table H-3

Annual Number of Shipments for the Reference 1,000 MWe Reactor

Material
Unirradiated fuel (truck)
Spent fuel (truck)
Spent fuel (rail)
Radioactive waste (truck)
(a)
(b)

Annual Number of Shipments for Typical Distance, Annual CO2(e)
the Reference 1,000 MWe Reactor1
mi(a)
Emissions(b)
6
1,000
19
60
1,000
194
10
1,000
64
46
500
74

Source: NRC (1975-TN216), Table S-5.
Results are rounded to the nearest 1000 MT CO 2(e).

19
20
21

The total GHG emissions for fuel and waste transportation are approximately 352 MT per
reference reactor-year from Table H-3. Over a 40-year operating life for the reference
1,000 MWe reactor, the total is approximately 14,000 MT of CO2(e) emitted.

22
23
24
25
26
27
28
29
30

Given the various sources of GHG emissions discussed above, the NRC staff estimated the
total lifetime GHG footprint for the reference 1,000 MWe reactor to be about 990,000 MT
CO2(e), with a 7-year building phase, 40 years of operation, and 10 years of active
decommissioning.6 These components of the GHG emissions footprint are summarized in
Table H-4. The uranium fuel cycle component of the footprint is the largest portion of the overall
estimated GHG emissions and is directly related to the assumed power generated by the plant.
The GHG emission estimates for the uranium fuel cycle are based on newer enrichment
technology, assuming that the energy required for enrichment is provided by modern regional
electric systems.
Under the NRC’s regulations, a reactor licensee has up to 60 years to complete the decommissioning of a reactor
facility commencing with the licensee’s certification that it has permanently ceased reactor operations (10 CFR
50.82(a)(3); TN249). The 60-year decommissioning period may be exceeded subject to NRC approval if necessary to
protect “public health and safety.” Id. The estimated 10-year decommissioning period is a subset of the 60-year
decommissioning period, during which significant demolition and earth-moving activities may occur (e.g., deployment
and operation of equipment at the decommissioning site and shipments by truck or rail to remove irradiated soil,
rubble, and debris from the site), as discussed in Supplement 1 to NUREG–0586 (NRC 2002-TN665).
6

H-4

Table H-4

Nuclear Power Plant Life-Cycle Green House Footprint
Activity Duration
(yr)(a)
7
7
40
40
40
40
10
10
40

Source
Construction equipment
Construction workforce
Plant operations
Operations workforce
Uranium fuel cycle
Fuel and waste transportation
Decommissioning equipment
Decommissioning workforce
SAFe STORage workforce
TOTAL(b)

Total Emissions
(MT CO2(e))
39,000
43,000
181,000
136,000
540,000
14,000
19,000
8,000
10,000
990,000

(a) Nuclear power plant life-cycle for estimating GHG is assumed to be 97 years which includes construction
(7 years), operations (40 years), and decommissioning (50 years).
(b) Results are rounded to the nearest 1,000 MT CO 2e.

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

The Intergovernmental Panel on Climate Change (IPCC) released a special report about
renewable energy sources and climate change mitigation in 2012 (IPCC 2012-TN2648).
Annex II of the IPCC report includes an assessment of previously published works on life-cycle
GHG emissions from various electric generation technologies, including nuclear energy. The
IPCC report included only reference material that passes certain screening criteria for quality
and relevance in its assessment. The IPCC screening yielded 125 estimates of nuclear energy
life-cycle GHG emissions from 32 separate references. The IPCC-screened estimates of the
life-cycle GHG emissions associated with nuclear energy, as shown in Table A.II.4 of the IPCC
report, ranged from 1 to 220 g of CO2(e)/kWh, with 25th percentile, 50th percentile, and 75th
percentile values of 8 g CO2(e)/kWh, 16 g CO2(e)/kWh, and 45 g CO2(e)/kWh, respectively. The
range of the IPCC estimates is due, in part, to assumptions regarding the type of enrichment
technology employed, how the electricity used for enrichment is generated, the grade of mined
uranium ore, the degree of processing and enrichment required, and the assumed operating
lifetime of a nuclear power plant. The NRC staff’s life-cycle GHG estimate of approximately
990,000 MT CO2(e) for the reference 1,000 MWe reactor is equal to about 3.5 g CO2(e)/kWh,
which places the NRC staff’s estimate at the lower end of the IPCC estimates in Table A.II.4 of
the IPCC report. This placement is primarily because the IPCC estimates were for LWRs that
used enrichment technologies that were based on the use of coal-fired generation as the
electricity source.

21
22
23
24
25

The GHG emissions presented in Chapter 3 of this generic environmental impact statement use
the values presented in this appendix but are scaled based on previous new nuclear reactor
reviews. The GHG emissions for building and operation (including the fuel waste and
transportation of fuel and waste) are discussed in Section 3.3, and in Section 3.16 for
decommissioning.

H.1

27
28

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, “Domestic Licensing of
Production and Utilization Facilities.” TN249.

References

H-5

1
2

10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, “Environmental
Protection Regulations for Domestic Licensing and Related Regulatory Functions.” TN250.

3
4
5

6
7

AEC (U.S. Atomic Energy Commission). 1974. Environmental Survey of the Uranium Fuel
Cycle. WASH–1248, Washington, D.C. ADAMS Accession No. ML14092A628. TN23.

8
9
10
11
12

Cefic and ECTA (European Chemical Industry Council and European Chemical Transport
Association). 2011. Guidelines for Measuring and Managing CO 2 Emission from Freight
Transport Operations. Brussels, Belgium. Accessed March 21, 2021, at
https://www.ecta.com/resources/Documents/Best%20Practices%20Guidelines/guideline_for_m
easuring_and_managing_co2.pdf. TN6966.

13
14
15
16

Chapman, E.G., J.P. Rishel, J.M. Niemeyer, K.A. Cort, and S.E. Gulley. 2012. Assumptions,
Calculations, and Recommendations Related to a Proposed Guidance Update on Greenhouse
Gases and Climate Change. PNNL-21494, Pacific Northwest National Laboratory, Richland,
Washington. ADAMS Accession No. ML12310A212. TN2644.

17
18

EPA (U.S. Environmental Protection Agency). 2012. “Clean Energy: Calculations and
References.” Washington, D.C. ADAMS Accession No. ML12292A648. TN2643.

19
20
21
22

EPA (U.S. Environmental Protection Agency). 2012. “Stationary Internal Combustion Sources.”
Chapter 3 in Technology Transfer Network Clearinghouse for Inventories & Emissions Factors:
AP-42. Fifth Edition, Research Triangle Park, North Carolina. ADAMS Accession No.
ML12292A637. TN2647.

23
24
25

FHWA (Federal Highway Administration). 2012. “Highway Statistics 2010 (Table VM-1).” Office
of Highway Policy Information, Washington, D.C. ADAMS Accession No. ML12292A645.
TN2645.

26
27
28

IPCC (Intergovernmental Panel on Climate Change). 2012. Renewable Energy Sources and
Climate Change Mitigation—Special Report of the Intergovernmental Panel on Climate Change.
Cambridge University Press, Cambridge, United Kingdom. TN2648.

29
30

Napier, B.A. 2020. Non-LWR Fuel Cycle Environmental Data. PNNL-29367, Revision 2,
Richland, Washington. ADAMS Accession No. ML20267A217. TN6443.

31
32
33

34
35
36
37

NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact
Statement of Decommissioning of Nuclear Facilities: Regarding the Decommissioning of
Nuclear Power Reactors. NUREG–0586, Supplement 1, Volumes 1 and 2, Washington, D.C.
ADAMS Accession Nos. ML023470327, ML023500228. TN665.

H-6

1
2
3
4

5
6
7
8
9
10

UniStar (UniStar Nuclear Energy, LLC). 2007. Technical Report in Support of Application of
UniStar Nuclear Energy, LLC and UniStar Nuclear Operating Services, LLC for Certificate of
Public Convenience and Necessity Before the Maryland Public Service Commission for
Authorization to Construct Unit 3 at Calvert Cliffs Nuclear Power Plant and Associated
Transmission Lines. Public Service Commission of Maryland, Baltimore, Maryland. ADAMS
Accession No. ML090680053. TN1564.

11
12
13
14

H-7

NRC FORM 335

U.S. NUCLEAR REGULATORY COMMISSION

(12-2010)
NRCMD 3.7

BIBLIOGRAPHIC DATA SHEET

1. REPORT NUMBER
(Assigned by NRC, Add Vol., Supp., Rev.,
and Addendum Numbers, if any.)

(See instructions on the reverse)

2. TITLE AND SUBTITLE

Generic Environmental Impact Statement for Licensing of New Nuclear Reactors
Draft Report for Comment

NUREG-2249
Draft Report
3. DATE REPORT PUBLISHED
MONTH

YEAR

September

2024

4. FIN OR GRANT NUMBER

5. AUTHOR(S)

6. TYPE OF REPORT

See Appendix A of this Report

Technical
7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if
contractor, provide name and mailing address.)

Office of Nuclear Material Safety and Safeguards
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001
9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear
Regulatory Commission, and mailing address.)

Same as 8 above.
10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

The U.S. Nuclear Regulatory Commission (NRC) staff prepared this generic environmental impact statement (GEIS) in
accordance with the National Environmental Policy Act of 1969 (NEPA), as amended, to address the NRC licensing of
the building and operation of new nuclear reactors in the United States. In this GEIS, the NRC staff uses the values and
assumptions in a technology-neutral plant parameter envelope (PPE) for a new nuclear reactor to evaluate the
environmental impacts of constructing and operating a nuclear reactor. In addition, this GEIS assumes that a new
reactor might be built anywhere in the United States that meets the requirements of the NRC’s siting regulations. To
accommodate this broad range of siting possibilities, the staff developed a site parameter envelope (SPE) that provides
limiting values and assumptions related to the site. The results from this GEIS will be codified in Title 10 of the Code
of Federal Regulations Part 51.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

Generic Environmental Impact Statement for Licensing of New Nuclear Reactors
New Reactor GEIS
NUREG-2249
National Environmental Policy Act
NEPA
New Reactor Licensing

13. AVAILABILITY STATEMENT

unlimited
14. SECURITY CLASSIFICATION
(This Page)

unclassified
(This Report)

unclassified
15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

@N
R
C
g
o
v

NUREG-2249
Draft

Generic Environmental Impact Statement for Licensing of New Nuclear Reactors

September 2024

File Type	application/pdf
File Title	Generic Environmental Impact Statement for Licensing of New Nuclear Reactors - Draft Report for Comment
Subject	Generic Environmental Impact Statement for Licensing of New Nuclear Reactors, New Reactor GEIS, NUREG-2249, National Environment
Author	U.S. Nuclear Regulatory Commission
File Modified	2024-09-09
File Created	2024-09-09