Based on lessons learned from past licensing activities and the novel design features of the advanced reactors, this paper sets forth six recommendations to streamline the NRC’s implementation of NEPA, including actions to improve pre-application meetings, site audits, the efficiency of NRC requests for additional information, and inter-agency consultations. The following recommendations described in this report are supported by case law, precedent set by other agencies, and specific examples:
- 1. Revise 10 CFR 51.20 to eliminate the list of NRC licensing actions that require an EIS and allow for the flexibility to use environmental assessments (EAs) and categorical exclusions for those licensing actions.
- 2. Increase the use of generic environmental impact statements (GEISs) to address issues and impacts that are expected to be common to most, if not all, advanced reactor designs.
- 3. Strengthen the regulations and guidance to require NRC staff to review and incorporate existing environmental analyses into a project’s EA or EIS.