Sunday, September 6, 2026

Comments due Sept. 10! NRC-2025-1237-0001 weakens radiation protection for caregivers; preempts tighter state regs...

Post comments here: https://www.regulations.gov/document/NRC-2025-1237-0001

(Here's what Sharon and I just submitted, NRC Comment Tracking Number: mtq-m7u1-38b4)

September 6, 2026

We oppose implementation of the changes in NRC-2025-1237-0001 which impact radiation standards for medical use of radioactive materials. We specifically ask the NRC to consider the comments and questions raised by the American College of Occupational and Environmental Medicine (ACOEM). (The ACOEM describes its members as "... the physicians who conduct medical surveillance of radiation workers, evaluate individuals after suspected overexposures, counsel patients and their families about radiation risk, and perform the causation analyses on which occupational illness compensation depends.")

The ACOEM states that: " ... the proposed rules as a whole reduces protection for workers, for caregivers, and for members of the public on a scientific record that the NRC itself describes as supporting the opposite conclusion." If this statement was the only concern raised about this proposed change to regulations, it should be sufficient to prevent the new rules from being implemented until the ACOEM's concerns are addressed.

The ACOEM raises important concerns about radiation exposure standards for caregivers such as a parent or spouse (quotes from the ACOEM's comment).

  • "Caregivers receive no radiation worker training, no individual monitoring, no medical surveillance, and no periodic dose accounting." Yet, the proposed standards would make it possible for caregivers to receive even more radiation than professionals whose dose limits are restricted by occupational safety standards.
  • There is no clarity about the total radiation a caregiver might receive. For example, a caregiver might be exposed to radiation while visiting the patient in a medical facility, and then be exposed to additional radiation while caring for the patient at home.
  • Special radiation limits exist for pregnant workers, but not for caregivers who may be pregnant.
  • The proposed regulations for caregiver exposure do not apply to minors, because minors cannot be designated as caregivers.

The reality is that minors and pregnant women may act as caregivers and they will almost surely be exposed to radiation if a patient is discharged for home care. It is better to acknowledge that people in these categories are particularly vulnerable to radiation and provide them with training, monitoring, and as much protection as possible.

Instead, in addition to not considering these special vulnerabilities for caregivers, the new regulation would reduce reporting requirements for radiation exposure to fetuses. The rational is that a patient might be unaware of her pregnancy when the radiation is administered. This is certainly a valid scenario, but it should not mean that the exposure to the fetus should not be reported. Instead, any child who was exposed to radiation in utero should have that fact as part of their medical record.

Finally, the ACOEM raises important points concerning state radiation protection standards, pointing out that under the proposed regulation: " ... a State could not retain an ALARA requirement, could not retain a ceiling on authorized public dose, and could not retain a lower caregiver dose allowance, even if its own legislature or radiation control program concluded that doing so was warranted for its population."

Throughout the nuclear era there have been efforts to relax the regulations for exposure to radiation. Leslie Groves claimed to have heard that severe radiation poisoning "is a pleasant way to die". In the latest attempts to reduce radiation protection, federal employees and others have promoted the blatantly false assertion that "Hormesis" is a thing — without a shred of evidence, and despite study after study indicating just the opposite: that LNT is a good approximation of radiation risk from exposure, down to the lowest possible measurable amount. BEIR VII confirmed it and literally thousands of individual research projects have contraindicated Hormesis. The physics of how the damage occurs was unknown when man-made radiation was introduced into society , but the fact that damage occurs was well-known before the Manhattan Project.

All ionizing radiation presents risks and should have a corresponding benefit to society. Both authors of this comment have benefited from the high doses of radiation given to diagnose and treat cancer patients (both are cancer survivors) and appreciate the work of organizations such as the ACOEM.

Even small radiation doses to vast numbers of people will cause cancers that need not have happened. Radiation exposure should ALWAYS be kept As Low As Reasonably Achievable (ALARA). These proposed rules will weaken protections for millions of people and will make it difficult for families and their medical providers to assess risks. For these reasons they should be abandoned.

We incorporate by reference and adopt as our own the comments submitted by the ACOEM (https://www.regulations.gov/comment/NRC-2025-1237-0006 tracking #: mtd-chbq-9vvg).

Sharon and 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



Thursday, August 27, 2026

The real reason for the sudden push for Small Nuclear Reactors (which will NEVER be "Modular" BTW so SMRs is the wrong name!)

It turns out (see below for one source) that the U.S. Government is "investing" billions of dollars in the future of inefficient, expensive, unreliable, complex, impossible to dispose of, Small Modular Reactors (SMRs). The real question is: WHY???

Face it: The reason has to be something sinister — it just has to be. Nuclear power always has a dark side (recall "Atoms for Peace" was just a cover to get the public to accept atoms for war (nuclear weapons)).

It turns out, it is sinister. Very sinister.

The United States military — currently run by the craziest, laziest, most ignorant ignoramus ever to lead an army — wants Small Modular Reactors. Specifically five of them, to be operating by 2028 (a date undoubtedly picked for political reasons). All five will be located on military bases in America.

How best to describe this? How about: One of the dumbest ideas in the history of dumb nuclear ideas! (And that's saying a lot.)

Meanwhile, dozens of senior military career officers are being unceremoniously fired by the ignoramus. Might this have been one of many things they knew was a bad idea? One would hope so...

At the moment, the "new, tougher, high-test[osterone] army" is "investing" $2.2 BILLION smackeroos (your tax dollars) to get its hands on these five SMRs. And they're to be mobile, as in mobile-Chernobyls (to recoin a phrase from yesteryear's nuclear waste transport plans to ship thousands of highly radioactive used reactor cores to Yucca Mountain, Nevada — which is technically still on the books as the ONLY solution to nuclear waste, even though it's cancelled AND was unworkable to begin with, when it was first proposed about half a century ago.

But the really crazy part is how vulnerable a nuclear reactor would be if it was deployed during a modern war. Think drone swarms, gravity bombs, unmanned tanks, robot soldiers that can outrun a horse, saboteurs, and general mayhem.

The plan, obviously, it to provide power to the fighting forces. So let's looks at that for a moment (which is more than enough time to see how stupid it is):

A typical SMR is expected to produce several hundred megawatts of electricity (roughly a third as much as a "modern" full-scale nuclear reactor (designed in the 1960s and 70s)). These five are called "Microreactors" and range from just one megawatt to twenty megawatts of power.

What would an army need these for? In an emergency would it feed into the civilian grid? (Not likely!) The bases would all still be connected to the local grid, though. Backup power for them, not for us. But of course, it's just a test. They want to take them into battle. Seriously!

To charge their phones? To charge their drones? To charge their robots, unmanned tanks, and the night-lights in their mobile bathrooms?

ALl of that, perhaps, but mainly, it's assumed, to power their own Data Center, which would also have to be mobile, and would also be a target. Data Centers are already targets during war, and — as with power — distributed data is the most resilient. What will the troops (or the robots) do when their Data Center is blown up (or its power source is disabled, or both, or the connections between the soldier (or robot) in the field and the Date Center are cut)?

One central power unit for what, several thousand troops? That's a target right there — and a rather easy-to-find one, at that! Despite shielding, any operating reactor is constantly emitting large quantities of high-energy rays and particles that are detectable with all sorts of "high-tech" equipment (they would be detectable with your phone if the phone manufacturers felt like adding a micro-sized radiation detector (which would barely raise the price and could provide a much-needed service in an emergency (I'm sure Herman Kahn would have approved!).

Besides that, mobile Data Centers would either be emitting radio-frequency communications to soldiers, robots or drones, or would have fiber-optic or other direct connections. Both Mobile SMRs and Data Centers would, in short, be high-value targets that are easy to find and difficult or impossible to protect.

The following corporations have all finalized contracts with the military to place nuclear reactors on five bases:

Antares Nuclear, Inc. – Deploying at Fort Bragg, North Carolina.

BWXT Advanced Technologies, LLC – Deploying at Fort Campbell, Kentucky.

General Atomics Electromagnetic Systems – Deploying at Fort Hood, Texas.

Radiant Industries, Inc. – Deploying at Fort Benning, Georgia (under a $750 million slice of the program).

Westinghouse Government Services – Deploying at Fort Drum, New York.

The claimed benefit? Resilient, localized backup.

At military bases in America!!! You would think (and Herman Kahn would certainly agree) that making the ENTIRE US GRID resilient would be a FAR BETTER choice for America — both for "defense" purposes as well as for the well-being of our citizens — and our soldiers.

However, these "microreactors" are supposed to be "mobile" reactors, and they're supposed to be deployed — it's MANDATED to have them OPERATIONAL by September, 2028! As if mandating it can FORCE it to happen. It's August, 2026 already, that's one heck of a time-frame to do the impossible — make a SAFE, RELIABLE nuclear reactor. It's not going to happen. They might build these "test" reactors, but they won't be safe or reliable. They might appear to be sort of reliable in peace, but during war they're vulnerable. And when one fails — even the smallest is expected to be large enough to power 1,000 typical U.S. homes, and most of them could power tens of thousands of homes. When that fails, due to the conditions of war, what's an army to do?

In America (if the fighting were on the home turf) the answer should be simple and obvious: plug into the resilient, reliable, civilian power grid (like they do now). Which would be virtually 100% reliable EVEN DURING WAR if it were powered by small-scale renewable energy.

Wind, wave, solar... with energy-dense batteries for backup.

Could you win a war that way? You can't win it with nuclear, that's for sure, because the "mobile" SMRs wouldn't be very mobile during a war: In all likelihood they would have to be shut down, cooled down, partially dismantled, transported (in pieces), and then re-assembled... while under fire and easy detection by the enemy.

Being on foreign soil isn't any better, since the attack could come from all sides — unless we're fighting together with allies, but we seem to have lost all of those, thanks to actions by the current Administration, such as threatening Greenland, NATO, Canada and even Switzerland, all in the last year, while senselessly and ruthlessly attacking smaller and weaker countries out of pure vanity, whilst committing war crimes all the while. This is not a recipe for peace in the world.

Whenever a nuclear reactor is available as a target for the enemy (see Bennett Ramberg's book on the subject) it must be protected. Nuclear reactors in America are — by law — at least minimally protected with armed guards, guard towers, high fences, lines-of-sight carefully thought out (not much use nowadays what with drone swarms the most likely attack vector)...

(Nuclear spent fuel, which is even more dangerous in many cases because there's so much of it in one place, isn't nearly as well guarded/protected, but harder to attack, thankfully. (Not hard enough to prevent it being a target in a thermonuclear war, for example, or by any terrorist hell-bent on destroying an entire state.)

Reactors being used in war are especially vulnerable targets. Disable ONE nuclear aircraft carrier and you put an entire air wing of our Navy out of action, perhaps sinking the carrier along with poisoning and drowning its crew. And you can do this from hundreds of miles away, if you've got a good "gravity bomb", which are nearly impossible to defend against (or if a friend of yours can give you one for a special occasion). One gravity bomb, well-aimed. And targeting is getting better all the time, all over the world.

Nuclear reactors are a waste of military money. The $2.2 Billion could be used for life-saving vaccines and aid to climate-stricken areas, of course — or it could be used to strengthen the civilian grid near each of the five chosen bases, which would be the BEST way to make the base's energy system RELIABLE EVEN IN TIME OF WAR, and the cheapest as well, for that matter. Or it could be used to install MOBILE solar and wind and non-lithium battery backups, easily carrying enough power to fight a modern war, which are only expected to last a few days (see Herman Kahn again, or listen to the current abomination in the White House, who announced he had "won" a war in three days that is still going on nearly six months later).

Ace Hoffman, Carlsbad, California USA

### Note: Nuclear expert Marvin Resnikoff commented on these reactors recently: "It is more than radioactive waste that is involved. SMR's require highly enriched uranium to operate for 8 years or more without refueling. To operate, reactors require water or sodium. To produce electricity, either PWR's or BWR's, require water as steam to turn a turbine."

The above essay was NOT written with AI (it went through about a dozen human edit passes by two humans instead) but is based on this google AI-based email that was passed around this morning:


https://share.google/aimode/tcH1Jn1mtik2a3Ix3

The U.S. Army is investing up to $2.2 billion over five years to deploy more than 20 commercial nuclear microreactors at domestic military installations. Announced under the Janus Program, this milestone-based initiative partners with the Defense Innovation Unit (DIU) to decouple critical defense infrastructure from potentially vulnerable civilian electrical grids. [1, 2, 3, 4]

Selected Companies and Military Bases

The Army has finalized contracts with five private vendors to build, own, and operate these systems at five initial base locations: [2, 5]

Antares Nuclear, Inc. – Deploying at Fort Bragg, North Carolina.

BWXT Advanced Technologies, LLC – Deploying at Fort Campbell, Kentucky.

General Atomics Electromagnetic Systems – Deploying at Fort Hood, Texas.

Radiant Industries, Inc. – Deploying at Fort Benning, Georgia (under a $750 million slice of the program).

Westinghouse Government Services – Deploying at Fort Drum, New York. [6, 7]

Key Specifications of the Microreactors

Power Output: Each microreactor will generate between 1 and 20 megawatts of electricity, roughly enough to sustain a small town. [7, 8] Grid Independence: The systems will operate on a "private wire" configuration. Bases remain connected to civilian grids, but microreactors act as a resilient, localized backup. [7, 9]

Mobility: Unlike massive conventional nuclear facilities, these factory-built modules are compact enough to be transported via truck, rail, or heavy cargo aircraft. [10, 11]

Timeline: Driven by Executive Order 14299, the Pentagon is legally mandated to have an operational nuclear reactor on a domestic military installation by September 30, 2028. [9, 12]

Why the Military is Going Nuclear

The military wants to replace its reliance on diesel backup generators, which present a logistically vulnerable fuel supply chain during conflicts. Advanced microreactors can operate for years without refueling, providing consistent baseload power capable of running energy-intensive, next-generation weapons systems and command centers. [4, 7, 13]

Furthermore, the U.S. Department of the Army intends for the Janus Program to serve as the "spear tip" for the commercial energy industry. By absorbing the initial financial and regulatory risks, the military is helping private developers scale up mass manufacturing to pave the way for civilian commercial use. [3, 7, 14, 15]

Are you tracking this deployment for its implications on defense technology, or are you more interested in how it affects the broader commercial nuclear energy sector?

[1] https://abcnews.com
[2] https://www.powermag.com
[3] https://www.army.mil
[4] https://www.houstonchronicle.com
[5] https://defensescoop.com
[6] https://www.defenseone.com
[7] https://www.krqe.com
[8] https://www.wsj.com
[9] https://neutronbytes.com
[10] https://www.nytimes.com
[11] https://www.armytimes.com
[12] https://www.bwxt.com
[13] https://www.reuters.com
[14] https://energy.media
[15] https://www.cnbc.com



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



Sunday, August 23, 2026

Comments due Aug. 26, 2026 for NRC-2025-1667-0001 which will weaken radioactive transport standards!

Regulations governing the packaging and transportation of radioactive material

Post comments here: https://www.regulations.gov/document/NRC-2025-1667-0001

This is what Sharon and I just posted, with NRC Comment Tracking Number mt6-m1cx-nl1k

August 23, 2026

We strongly oppose proposed changes to 10 CFR part 71 as described in NRC-2025-1667-0001 covering: " ... regulations governing the packaging and transportation of radioactive material ... ". The proposed changes are designed to: " ... support the future domestic deployment of microreactors and other similar new nuclear technologies ... ".

The proposed change would: "... Allow increased radiation level limits, under certain conditions ...", because there may be: "... accelerated timelines that may not allow for extended decay heat or radiation level reduction through post-irradiation cooling ...". So, instead of requiring a design and a transportation plan that meets radiation standards, the new version of Part 71 would reduce radiation protection.

If the proposed changes to Part 71 are implemented, companies that transport radioactive materials will save money. But the public (including unborn generations and people outside the United States) will pay the health and accident costs.

The NRC claims that: " ... the proposed rulemaking would not impact threatened or endangered species or critical habitat ...", but the NRC does not explain why, except to say that: " ... the proposed rule provisions would not have a significant effect on the quality of the human environment ... ". Whether or not the second statement is correct, what happens in the human environment may be totally different from what happens to animals living in a critical habitat such as a river, national forest, etc..

The proposed rule change says that: " ... transportation of radioactive material is one of the safest sectors of hazardous materials logistics ... " because there have been: " ... no recorded fatalities or serious injuries attributable to radiation exposure during transport or as a result of a transportation accident." How would we know? It is virtually impossible to prove that a particular radiation exposure led to a fatality or serious injury. Furthermore, under these regulations, thousands of reactors will be transported around the country, according to the NRC's own estimates. Serious accidents will be risked with each shipment. The totality of risk must be considered.

The NRC admits that fatalities and serious injuries can occur as a result of radiation exposure -- that's exactly why there are radiation standards. But the standards don't guarantee that no living things will die or suffer generational damage -- they only reduce the probabilities for "reference man". Increased levels of radiation exposure should only occur (if at all) after careful consideration of the true costs to the environment, to all humans (not just "reference man"), and to all living things. Alternatives, including wind and solar power, must be properly considered for their lower risk, lower cost, faster deployment, recyclable components, etc..

As a society, we should not accept that multiple generations could suffer genetic harm, for example just because a pregnant woman happens to be stuck in a traffic jam next to a vehicle that is carrying radioactive material that is allowed by the increased radiation limits of this new regulation.

This proposed change is one of many the NRC has published recently. As the NRC itself explained during a recent public meeting, all of these regulations are dependent on each other and the order in which they are approved matters. So, for instance, if this regulation is approved, any changes to 10 CFR Part 20 (Standards for Protection Against Radiation) might have to be revised. There are several ways this intertwined approval process might subvert the requirements of other regulations (both NRC regulations and those from other federal, state, and local agencies). For example, the proposed rule for Reforming and Modernizing the Radiation Protection Framework (https://www.regulations.gov/document/NRC-2025-1140-0001) has 576 comments as of August 23, 2026 whereas the proposed change to Part 71 (this regulation) has only 3 comments. However if the changes to Part 71 are approved first, many of the comments concerning Part 20 could be negated without evaluating the concerns that they raise.

Multiple groups, including other government agencies, have requested extensions of specific comment deadlines. For example, the Conference of Radiation Control Program Directors (CRCPD), requested a 15-day extension of the comment deadline for NRC-2025-1667-0001 (this proposed regulation). The CRCPD describes itself as the national nonprofit organization representing the radiation control programs of all 50 states, the District of Columbia, and the U.S. territories, and provided a clear explanation of why a small extension for this particular deadline would be useful.

We urge the NRC to reconsider the CRCPD's request for a comment-period extension, and to provide a clear answer concerning how comments on the overlapping proposals for rule changes will be reconciled.

Sharon & 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