Strengthening the NRC’s Environmental Review Framework

The NRC’s draft NUREG-2249, “Generic Environmental Impact Statement for Licensing of New Nuclear Reactors' (NR GEIS)”, improves the efficiency of environmental reviews for new nuclear reactors. As the demand for clean, reliable energy continues to grow, the NRC must streamline approaches that maintain regulatory efficiency while ensuring strong environmental protections. The NR GEIS aims to provide a comprehensive and technology-neutral framework for evaluating the environmental impacts of new reactors as directed by the NEIMA and the ADVANCE Act.

The Breakthrough Institute (BTI) supports using GEIS, as it is a critical tool for addressing the anticipated surge in nuclear reactor applications. However, BTI has identified several areas where the NR GEIS could be strengthened to better align with the needs of modern reactor designs and regulatory processes. For example, the analysis of greenhouse gas emissions needs to be broader to include smaller and larger reactor designs. Some classifications (such as “Need for Power” and “Purpose and Need”) in the proposed NR GEIS should be revised to avoid unintentionally limiting the necessary flexibility for the deployment of advanced nuclear reactors

Additionally, the NRC should consider the environmental impacts of not proceeding with nuclear projects. The “no-action” alternative, which involves not licensing new reactors, should be more thoroughly evaluated in the NR GEIS. BTI also urges the NRC to consider broader societal benefits associated with nuclear energy, such as its role in energy independence, local economic development, and national security. The NR GEIS should also be expanded to include non-power applications, such as research reactors and test facilities, which are often overlooked in traditional environmental impact assessments.

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