Thursday, September 10, 2026

Comments due Sept. 10, 2026! NRC-2025-1139-0001 can hinder public comment and remove advisory committees

Comments on these proposed regulatory changes are due TODAY, September 10, 2026!

Go here to leave a comment with the Nuclear Regulatory Commission: https://www.regulations.gov/document/NRC-2025-1139-0001

Below is what Sharon and I just posted a few minutes ago. (Comment Tracking Number: mtv-tp3p-l7uv )


The NRC describes this proposed rulemaking as non-controversial and plans to move directly to a final rule unless it receives " ... significant adverse comments ... ". (The final version of the rule has specific changes to 10 CFR, and is available here: https://www.regulations.gov/document/NRC-2025-1139-0002.)

It is generous to presume most of these changes are merely administrative. However, the wording of the rule doesn't make it clear what the actual impact of the changes will be, since, for example, "substantive" is an ambiguous term.

The final version of the rule has a long and detailed section devoted to "advisory committees" which is aimed at reducing the number and cost of such committees. What will the practical impact of such a change be for society, or the public, and for impacted individuals? The rulemaking does not make any of that clear, and leaves us with vague statements such as:

" ... changes are administrative and procedural in nature and do not introduce new substantive obligations for NRC licensees or other stakeholders ..."

" ... revisions affect terminology, chartering requirements, membership appointment processes, and reporting obligations ... "

Which advisory committees and advisors will be eliminated? Will the NRC be getting less input from industry organizations, such as the Nuclear Energy Institute (NEI), or from companies seeking nuclear licenses, or from experts in the field who do not have a vested interest? Numerous scientific studies support more-restrictive radiation standards — not less. Will support for that position be the first to be eliminated?

Similarly, the rulemaking changes the requirements for additional public comment periods after a rule is announced, because such comment periods were not actually required in some cases. (The NRC had made the requirement for these additional comment periods explicit in an 1985 amendment to 10 CFR, part 2.) The NRC explains the proposed reversal of that amendment by quoting the 1985 final rule which says: "The Commission normally provides for ... comment on policy statements and interpretive rules, and will continue to do so in the future."

However, it is not clear whether the entire 1985 amendment is being eliminated and therefore whether this vague reassurance has any weight. In addition, the underlying reasons for additional public comment periods are ignored in the new rule. How will making the extra comment period optional allow for exposing: " ... any errors or oversights that occurred in the formulation of the rule ... ” which was the intent or the 1985 change to 10 CFR part 2?

There is no discussion in the proposed rule changes for what might be lost by making current requirements for public comment periods discretionary. If the public had the opportunity to comment prior to this new rule — why shouldn't the rule specify that the NRC should give the public at least as much opportunity to comment as is currently available?

This change should be completely discarded.

Ace & Sharon 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



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 (images added to the blog version)



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