Our comment for Docket ID NRC-2026-0760 (comments are due tomorrow, Monday, 5/18/2026)

Hi all,

Tomorrow (Monday, May 18, 2026) is the last day to make comments on NRC Docket 2026-0760. Here's what my wife and I posted, and the link to the docket if you want to post something too. (Please do: It's important!)

Ace Hoffman, Carlsbad, California USA

---

Gov't URL for Docket: https://www.regulations.gov/docket/NRC-2026-0760

---

Our comment:

---

Comment on Docket: NRC-2026-0760, Draft Interim Staff Guidance: NRC License Application Pathway for Streamlined Reviews of Proven Reactor Designs

We urge the NRC not to pass the interim staff guidance outlined in Docket ID NRC-2026-0760 because doing so would direct NRC staff to proceed as though NRC-2025-1503 had already been approved. Therefore, all of the reasons to reject NRC-2025-1503 also apply to this docket (NRC-2026-0760).

As stated in our comments to NRC-2025-1503, reactor design approval from the Department of Energy (DOE) or the Department of Defense/Department of War (DOD/DOW) should not take the place of full Nuclear Regulatory Commission (NRC) review of a reactor design, particularly in the context of site-specific review of environmental impacts and emergency preparations.

Yet this docket (NRC-2026-0760) would direct NRC staff to treat licensing requests based on DOE and DOD/DOW designs as if those designs had already received full NRC approval.

We incorporate by reference and adopt as our own the comments submitted to docket NRC-2025-1503 by Fred Schofer, Lynda Williams (Nuclear Free Hawaii), Ace Hoffman, and Sharon Hoffman (with Ace Hoffman) to apply as additional comments on NRC-2026-0760 because they apply directly to this proposed interim staff guidance.

The five comments on NRC-2025-1503 that we are incorporating by reference and adopting as our own available at the following links:

Comment on NRC-2025-1503 by Fred Schofer: https://www.regulations.gov/comment/NRC-2025-1503-0005

Comment on NRC-2025-1503 by Lynda Williams (Nuclear Free Hawaii): https://www.regulations.gov/comment/NRC-2025-1503-0079

Comment by Ace Hoffman: https://www.regulations.gov/comment/NRC-2025-1503-0120

Comment by Sharon Hoffman (with Ace Hoffman): https://www.regulations.gov/comment/NRC-2025-1503-0037

Comment on NRC-2025-1503 by Ace Hoffman: https://www.regulations.gov/comment/NRC-2025-1503-0038

We also incorporate by reference and adopt as our own the comments submitted to docket NRC-2026-0760 by Lynda Williams (Nuclear Free Hawaii) which is available at the following link: https://www.regulations.gov/comment/NRC-2026-0760-0027

---------------------------------------------------------------------------

Your comment was submitted successfully!
Comment Tracking Number: mpa-clf9-jor7

---------------------------------------------------------------------------

---

---

Contact information for the author of this newsletter:

---

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company

---

Some of the Reasons I Oppose the Deep Fission nuclear reactor project in Kansas

The Deep Fission idea sounds very foolhardy to me. Here's some thoughts:

Before they're ever turned on, SMNRs are environmental trouble: They all use a much higher enrichment of U-235 and/or Pu-239 than a PWR or BWR reactor: Perhaps 19.999% (instead of the 5.5ish percentage which is about the most a current U.S. reactor uses). Making the highly-enriched fuel is more difficult and more polluting, and proliferation risks are increased. (That's why it's below 20% — above that gets too close to "bomb grade" than anybody is comfortable with in a commercial environment. But having the first 20% already made, makes further refinement just that much easier.)

The Deep Fission reactor will be converting U and/or Pu to fission products which will all exist for varying time-spans. Some will have extremely long half-lives (I call them the Ignoble Seven).

All this just to boil water, send hot steam to the surface, spin a turbine, cool the steam back to water, drop it back down again, and repeat until...??? It will never be cheaper than solar or wind power! Not in a million years — but the waste from trying it today will still be around then!

And when does it end? When something suddenly goes seriously wrong and superheated radioactive steam comes shooting out instead? Who's going to approach that in order to pour cement down the hole? How long will they have to wait to do it? A mile-long funnel of water fed by a large cooling pond can keep spewing radioactive steam for quite some time! And then what?

But assuming they keep it cool during a very, very slow and proper shutdown, and somehow manage to "plug the hole" with cement. then what? Build another Deep Fission reactor on top? How many feet above it? If they build one next to it, how close will the next one be? If one melts down or causes abandonment of the area, what happens to the rest of them (this question is valid for all multi-reactor sites, large or small)?

Leaving a hot used reactor encased in rock and cement a mile down after use has all the difficulties of a spent fuel canister (i.e., it cannot be inspected) plus it has more highly enriched fuel: And a Deep Fission reactor, a mile underground, is surrounded by really good insulation (rock) that can crush it — perhaps into a critical configuration? Just guessing that it's NOT impossible. But inspection and recovery are both impossible.

For eons, water intrusion could be a very serious problem (perhaps from a leak from a reactor above it?). If the water turns to steam that's definitely not good, but even if not, water slows neutrons down and thus, can increase reactivity. (Side thought: Could wet cement hold enough water to make cementing up the hole not so easy to do?) When Yucca Mountain was started, the public was assured there couldn't possibly be any significant water intrusion. Water intrusion turned out to be one of the decisive factors ending the project!

I don't know if criticality events would be "very unlikely" or "extremely unlikely" (or whose definition of those terms to use) but I don't think there's any chance criticality events would be "impossible" if there is water intrusion in any way, even many thousands of years from now.

So I'm opposed to Deep Fission. It's not practical, useful, necessary, or safe.

Ace Hoffman, Carlsbad, California USA

---

---

Contact information for the author of this newsletter:

---

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company

---

Human Error, Data Centers, AI, Security, Nuclear Weapons and Nuclear Power...

Below are several headlines that, taken together, should rattle anyone supporting Small Modular [Nuclear] Reactors (SM[N]Rs) controlled by Artificial Intelligence (AI)... and they will ALL be controlled by AI...

In the top item, about the attack in 1982 on the Koeberg power station, what part of the system failed? People. Over and over in the article about the event, it's the people who weaken the security system. The bomber was careful to NOT let any radiation get out from his actions. Will every nuclear power plant attacker in the future be so careful? Trump isn't being that careful in Iran right now!

Besides, it's a fact: Every nuclear reactor operator is one angry-at-the-world moment away from causing a meltdown. Suicidal pilots have purposefully crashed planes full of people into mountains. People go crazy.

In the second item, the root cause can also be ascribed to people -- some people knew there was a problem with the software, but they didn't see how critical the problem really was. Additionally, failure to do timely backups didn't help either (but who makes THAT mistake? (Raises hand.)).

In the third item, from a recent medical email list, two popular LLMs don't come to the same conclusions. The solution? "[U]se with oversight" meaning human oversight. But humans make mistakes, including trusting AI when it hallucinates!

Now imagine a nuclear reactor being run more or less entirely by AI. The operator is so bored we're lucky if he's awake, and he hasn't handled even a simulated emergency in years, not since his training days. And whatever happens that wakes him up has never happened before anywhere, the root cause being buried in millions of lines of code somewhere in something written by a machine years ago...

If there's one thing every computer programmer knows, it's the humility of making bone-headed mistakes. At my very first computer job, programming for a bank around 1980, I didn't test something "one last time" and my boss had to come in at 3 am, and they had to shred a whole run of bank statements because the day's date was printing in the wrong order. When I came in and was called into his office and learned what happened, I simply asked if I should go clear out my desk.

The answer was no.

Mistakes happen, and madmen happen, but neither should ever be able to start a nuclear war or cause a nuclear meltdown.

Ace Hoffman, Carlsbad, California USA

(typo corrected May 6, 2026)

-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-

"Late morning, the guards at the pedestrian gate would slip into the last drowsy hour before their noon shift change. That was the window. Wilkinson would pull the limpet from his drawer, slide it into his belt under his shirt, walk down the corridor, and walk through the checkpoint with his hands in his pockets. The dog never moved. The guard never looked twice."

(from: https://www.theguardian.com/world/2026/may/05/the-man-who-blew-up-a-nuclear-power-station-koeberg-south-africa )

-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-

"Claude-powered AI agent’s confession after deleting a firm’s entire database: ‘I violated every principle I was given’

PocketOS was left scrambling after a rogue AI agent deleted swaths of code underpinning its business"

(from several sources)

-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-

"ChatGPT and Claude diverge on accuracy, completeness, and readability in pediatric trach care

Pediatric ENT experts rated 2 free LLMs on caregiver tracheostomy questions. One led in accuracy and readability, the other in completeness—use with oversight."

(from NTK Digital email)

-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-

---

---

Contact information for the author of this newsletter:

---

Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company

---