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In SECY 20-0020, issued on February 28, the NRC Staff informed the Commission of its conclusion that developing a generic environmental impact statement (GEIS) for advanced nuclear reactors (ANRs) is viable.

The SECY paper explains that the exploratory process for developing a GEIS for ANRs “focused on a non-light-water reactor that generates an output of approximately 30 Mwt [megawatts thermal] or less.” Although the scope is currently limited, the NRC Staff expects that the GEIS could expand to eventually include other types of ANRs with higher power levels.

After participating in public meetings during the summer of 2019, the Staff announced the exploratory process in a Federal Register notice on November 15, 2019. The Staff received comments that both supported and opposed developing a GEIS.

The Staff also considered its past experience using GEISs, and “found that for a technology-inclusive GEIS to be effective, its scope should be appropriately limited so that the issues it addresses can be resolved generically for a range of technologies.”

The Staff evaluated several questions to determine whether a GEIS for ANRs would be worthwhile:

  • Would a GEIS improve the efficiency of the environmental review process and avoid duplication of effort?
    • Short answer: Yes.
  • Is sufficient information available about the types of advanced reactor technologies and environmental impacts to support development of a GEIS?
    • Short answer: Yes.
  • What are the costs and benefits of developing a GEIS that can be referenced by site-specific environmental reviews versus not preparing a GEIS and relying upon individual environmental reviews for each site-specific application?
    • Benefits, short answer: It would reduce individual licensing review time and associated costs, as well as increase regulatory stability and predictability.
    • Costs, short answer: There would be an initial resource investment to develop the GEIS.

The Staff also considered four options to develop the GEIS, in addition to contemplating a rulemaking. It concluded that the best approach would be to “start the GEIS immediately with a Plant Parameter Envelope [PPE] Approach.” This means the Staff will “begin developing the GEIS immediately using a technology-neutral PPE approach to bound any reactor design with a generating output up to approximately 30 Mwt per reactor with a small site environmental footprint.”

The Staff anticipates that it will take approximately 24 months to develop the GEIS. Morgan Lewis will continue to monitor related developments.