ENVIRONMENTAL & SITING

Over time, implementation of the National Environmental Protection Act (NEPA) in the United States and the IAA in Canada have both become more complex and time-intensive, with reviews frequently spanning several years or more and requiring significant resource expenditures. Maintaining the status quo will hinder the timely licensing of the advanced reactors. To achieve widespread deployment of advanced reactors, the implementation of NEPA and IAA must be streamlined to achieve efficient and timely environmental reviews.

Since 2023, the United States has made progress to streamline environmental and siting reviews for nuclear projects. The 2023 BUILDER Act imposed strict time and page limits on NEPA documents to reduce delays, while the 2024 ADVANCE Act directed the NRC to modernize its NEPA framework to ensure efficient, timely, and predictable reviews of reactor applications. President Trump’s May 2025 executive order on NRC reform reinforces these legislative directives. Most recently, the NRC issued a Staff Requirements Memorandum (SRM-SECY-24-0046) approving staff recommendations to revise its regulations, expand categorical exclusions, narrow alternatives analyses, and enhance interagency coordination—together marking a major shift toward faster, more practical environmental reviews for nuclear deployment. To fully implement these changes, which are critical to its ability to timely process and review a potentially large volume of pending and anticipated license applications, the NRC must complete substantial updates to its NEPA regulations, guidance, and policies in 2026.

Canadian industry is working diligently with government to streamline the IAA process to facilitate efficient approvals while continuing to ensure environmental and human health safety and improve Indigenous engagement. At the same time, industry is working with the CNSC to address issues related to regulatory burden in the licensing process.

Key Issue: Categorical Exclusions (United States Only)

Current NRC regulations (10 CFR 51.20(b)) require the NRC to prepare an environmental impact statement (EIS) for specific categories of actions, including permits/licenses to construct and operate a nuclear power reactor or testing facility under 10 CFR Part 50 or Part 52. This requirement does not reflect consideration of the innovative design features, smaller source terms, and safety characteristics of advanced reactors, which are expected to result in even smaller site preparation/preconstruction, construction, and operation-related impacts relative to current large LWRs. Also, as relevant to DOE-funded, NRC-licensed projects and other DOE-sponsored projects, DOE’s categorical exclusion regulations at 10 CFR Part 1021, Subpart D, do not fully account for the novel characteristics and reduced impacts of advanced reactors. Thus, current regulations are not consistent with directives contained in the 2023 Fiscal Responsibility Act amendments to NEPA, Section 506 of the ADVANCE Act of 2024, and May 2025 executive orders that call for the expanded use of existing and new categorical exclusions for advanced reactors.

ACTION:

Priority

Status

Enable NEPA exclusions: Develop input to the NRC and DOE that supports the development, implementation, and adoption of proposed categorical exclusions under NEPA and 10 CFR Part 51 for advanced reactor licensing and/or operation.

Action Owner: NEI

Need Date: 2026 for continued engagement with regulators

Progress to Date on Addressing Key Issue: NEI has provided detailed input to NRC and DOE to support the development, implementation, and adoption of proposed categorical exclusions under NEPA, 10 CFR Part 51, and DOE’s new NEPA-implementing procedures for advanced reactor licensing and/or operation. Separately, the NRC staff has proposed use of a multi-option, staged approach to licensing NOAK microreactors that includes the development of categorical exclusions, on a case-by-case basis, for standard microreactor designs through rule-making. Such future rule-making(s), which still require Commission authorization, should provide appropriate vehicles for NRC to develop and implement changes to its categorical exclusion regulations. In SRM-SECY-24-0046, the Commission directed the NRC staff to consider establishing categorical exclusions for microreactor licensing, advanced demonstration projects, and site envelopes for specific reactor technologies.

Key Issue: Environmental Assessments

Current NRC regulations (10 CFR 51.20(b)) require the NRC to prepare an EIS for specific categories of actions, including permits/licenses to construct and operate a nuclear power reactor. This requirement does not reflect consideration of the innovative design features, smaller source terms, and safety characteristics of advanced reactors, which are expected to result in even smaller site preparation/preconstruction, construction, and operation-related impacts relative to current large LWRs. In Staff Requirements Memorandum SECY-21-0001 (April 19, 2022), the NRC noted that their staff may “further explore the idea of preparing environmental assessments to meet NEPA requirements for some categories and subcategories of license applications presently falling within the scope of 10 C.F.R. § 51.20(b).”

For Canada, the objective is one project, one assessment, with one decision. It will be key to coordinate CNSC’s licensing reviews with the provincial or territorial environment assessment process. Reviews of second-of-a-kind and fleet deployments need to take credit for assessments of safety performed in FOAK deployments and focus instead on the site-specific project differences.

ACTION:

Priority

Status

Enable EAs in place of EIS: Develop input to the NRC that supports the expanded use of EAs in lieu of more detailed EISs for the licensing of certain advanced reactors, consistent with recent legislative directives and the expected minimal environmental impacts of such reactors.

Action Owner: NEI

Need Date: 2026 for continued engagement with regulators

Progress to Date on Addressing Key Issue: NEI has provided input to NRC specifically advocating for revisions to 10 CFR 51.20 that would allow expanded use of EAs/findings of no significant impact (FONSIs), including mitigated FONSIs, instead of EISs. The NRC staff recommended to the Commission initiating a rule-making that would revise 10 CFR 51.20 to allow on a case-specific basis whether an EA rather than an EIS or supplemental EIS is appropriate for a particular nuclear reactor application. The Commission approved that recommendation in SRM- SECY-24-0046. It also directed the NRC staff to evaluate the benefits of codifying mitigated FONSIs into NRC’s regulations versus continued reliance on guidance documents.

Priority

Status

Streamline the Canadian IAA and CNSC EA for advanced reactors, specifically:

  • Short term: Ensure no delays at the regulator end to the legislated or regulated assessment timelines. Drive for Tailored Impact Statement Guidelines that have appropriate scope for nuclear projects.
  • Medium term: Revise implementing regulations to streamline the process and shorten timelines, especially as applied to NOAK and fleet deployments, to require only assessment of site-specific aspects, not reassessment of aspects addressed at other sites
  • Revise federal acts and provincial legislation to recognize the climate-change imperative and environmental benefits of nuclear power. Revise legislative requirements appropriately to enable faster, more predictable deployment of energy sources that do not emit greenhouse gases.
  • Encourage federal government to provide clarity on Indigenous engagement and consideration of FPIC. Ensure CNSC has resource and legislative capacity to carry out Indigenous engagement

Action Owner: CNA working with the Canadian federal government and provincial agencies

Need Date: 2025, sustained

Key Issue: Generic Environmental Impact Statement (United States Only)

NRC has prepared a draft generic environmental impact statement (GEIS) (NUREG-2249) to address NRC licensing of the construction and operation of new nuclear reactors in the United States, as well as a proposed rule that would amend the NRC’s Part 51 regulations by codifying the findings of the GEIS. By allowing applicants for advanced reactors that meet the performance measures and assumptions in the GEIS to reference the GEIS in their applications, the GEIS is expected to simplify and expedite advanced reactor environmental reviews.

ACTION:

Priority

Status

Support the successful implementation of GEIS: Participate in the NRC rule-making process and provide technical and legal input to ensure that the agency’s final new reactor GEIS, associated rule, and implementing guidance meet the agency’s objective to “streamline the time and effort needed to complete environmental reviews under NEPA for most advanced nuclear reactors.”

Action Owner: NEI

Need Date: 2026 for continued engagement with regulators

Progress to Date on Addressing Key Issue: The Commission authorized NRC staff to proceed with the proposed rule in April 2024 and directed the staff to make the GEIS applicable to any new nuclear reactor application that meets the bounding values and assumptions in the GEIS. NRC staff published the draft new reactor GEIS, proposed rule, and regulatory guidance for public comment in October 2024 and received comments through December 18, 2024. The staff is expected to submit the revised GEIS and proposed rule to the Commission by the end of 2025 and issue a final GEIS and rule in 2026.

Key Issue: Population Siting (United States Only)

The existing population-related siting guidance is prescriptive and based on large LWR technology. NRC guidance and expectations for population-related siting of advanced reactors should appropriately consider their smaller source terms and safety characteristics through the use of technology-inclusive, RIPB criteria.

ACTION:

Priority

Status

Develop technical input to siting criteria: The industry will provide technical input to support NRC’s preparation of guidance on technology-inclusive, RIPB criteria for the policy on siting away from population centers that will increase the number of allowable sites for advanced reactors in comparison to current guidance while still controlling societal risks.

Action Owner: NEI

Need Date: 2026 for continued engagement with regulators

Progress to Date on Addressing Key Issue: NEI submitted a white paper12 that proposes a RIPB, and consequence-oriented approach to revising NRC’s current population-related siting requirements in June 2025.

12”Modernizing Population-Related Siting Requirements for Advanced Reactors.” NEI White Paper ML25171A127

Key Issue: Site Selection and Evaluation (United States Only)

The site selection process requires the collection of significant safety and environmental information and detailed analysis that must be supplied to the NRC to support an applicant’s siting decision. A site must meet NRC regulatory requirements for construction and operation (that is, requirements related to site suitability and radiological health and safety). An applicant also must comply with environmental review requirements under NEPA and 10 CFR Part 51 for the consideration of alternative sites. Some requirements might be outdated or inapplicable due to advancements in reactor technologies and analytical methods, expected new non-electric applications of advanced reactors (such as process heat), and the 2023 amendments to NEPA. The process the NRC uses to determine the environmental impact is currently in flux and updated actions may be needed in the near future.

ACTION:

Priority

Status

Develop guidance for site selection and evaluation: The guidance will focus on simplifying and streamlining the site selection and site suitability evaluation processes for advanced reactors, including reactors that might be sited on former coal-fired power plant sites.

Action Owner: NEI

Need Date: 2026

Progress to Date on Addressing Key Issue: The NRC Commission approved SECY-24-0046 to streamline the NRC’s analyses of alternatives, including the analysis of alternative sites. NRC staff also proposed, in SECY-25-0052, a framework for graded site characterization to significantly reduce the burden of site characterization for designs with significant safety margin.

EPRI’s Siting Guide13 has been updated to reflect significant changes in the landscape for new nuclear plant deployment; update references, data sources, and lessons learned; and review for completeness with respect to social, economic, and environmental justice considerations.

Key Issue: Increasingly Stringent Permitting Process

Population growth, climate change, pollution, and aging water delivery systems have created an increasing array of challenges with water supply, water quality, ecological impact, and infrastructure. As a result, many permitting agencies have been adopting increasingly stringent water quality standards and thermal discharge limitations that make permitting closed-cycle wet cooling plant designs increasingly difficult, if not impractical.

ACTION:

Priority

Status

Use best waste heat cooling technologies to ease permitting process: Develop guidance on available cooling water technologies and cooling water system design options to help applicants using water-cooled advanced reactor technologies avoid or mitigate challenges related to cooling water availability and permitting.

Action Owner: Owner with guidance from EPRI

Need Date: 2023 for guidance (complete)

Priority

Status

Develop a methodology for alternate data sources for meteorological data: The intent of this methodology is to leverage National Oceanic and Atmospheric Administration (NOAA) and other data sources in lieu of site-specific meteorological towers to enable more efficient siting and licensing and to reduce unnecessary regulatory burdens without compromising safety.

Action Owner: NEI

Need Date: 2026

Priority

Status

Develop a methodology for alternate data sources for seismic and geologic data: The intent of this methodology is to leverage United States Geological Survey (USGS) and commercial site investigations in lieu of traditional boring methodologies to enable more efficient siting and licensing and to reduce unnecessary regulatory burdens without compromising safety.

Action Owner: NEI

Need Date: 2026

Progress to Date on Addressing Key Issue: EPRI report 3002026571 14 provides an overview to guide the initial selection and design of cooling system technology for a Rankine power cycle for electricity generation to assist project with selecting the optimal technology.

NEI has developed and submitted a report15 proposing alternate data sources, such as NOAA met stations, state mesonets, and FEMA emergency weather stations, for NRC endorsement to allow for an easier process of collecting the needed weather data.

NEI has begun work, including stakeholder engagement, on a proposed graded approach to seismic hazard analysis and corresponding site characterization. that builds on reports from NEI16 and NRC.17 A Fall 2025 submittal of the report to the NRC for endorsement is expected.


14Program on Technology Innovation: Nuclear Reactor Heat Rejection Configurations-Assessment of Cooling System Technologies for Advanced Reactors, Palo Alto, CA: EPRI. 300202657 
15ML25064A310 “NEI Proposal for Offsite Met Data Sources,” March 2025.  
16ML24213A337 “Regulations of Rapid High-Volume Deployable Reactors in Remote Applications and Other Advanced Reactors,” July 2024.  
17ML24309A266 “Nth-of-a-Kind Micro-Reactor Licensing and Deployment Considerations” July 2025.