Comments on NRC-2025-0379-0011 must be submitted before 11:59pm EDT on Monday (June 15, 2026)!!

Link to submit comments: https://www.regulations.gov/document/NRC-2025-0379-0011

Here is what we just submitted (our confirmation code is mqe-edcg-toht )

We strongly oppose the rulemaking defined by NRC-2025-0379-0011, which would make it easier to license new nuclear reactor designs with nowhere near the level of regulation that has been used for all commercial reactors to date.

The stated intent is: "... to establish a licensing pathway for factory-fabricated microreactors and other low-consequence reactors." Every reactor will produce large quantities of unmanageable, highly toxic radioactive waste, starting the day they are turned on. Therefore, there can never be a guarantee that accidents to either the reactor or its spent fuel will be "low-consequence".

We do not need a new licensing pathway for nuclear reactors, we do not need new reactor designs, and most of all, we do not need any more nuclear waste.

Every ounce of nuclear waste that has ever been created (and that hasn't already been lost to the environment) is still in "temporary storage" because it is impossible to guarantee safe permanent storage for materials that will be dangerous for longer than civilization has lasted. So NOBODY wants the waste.

New reactors will create new hazardous waste streams, regardless of type (TRISO, MOX, HALEU, FAFO*, etc.).

No SMR (Small Modular Reactor) is likely to be more efficient (that is, more cost-effective) than today's large reactors. And because they'll be LESS efficient, they will produce MORE nuclear waste per kilowatt of energy produced. And there will be nothing "small" about the financial costs or the environmental risks.

This and other ongoing attempts to destroy proper regulation of nuclear power in the United States make it clear that nuclear technology is unsustainable and unsafe.

If it was safe, you wouldn't need to relax the safety regulations and cap the insurance level with Price-Anderson.

If it was cost-effective, you wouldn't need to subsidize it.

This rulemaking doesn't focus on protecting the public or the environment. Rather, the rulemaking is concerned with making it easier for stakeholders (meaning companies that might profit) to license new (or previously tried-and-failed) reactor designs. Concurrently, the rulemaking ignores the very real stakes for people living near new reactors or waste disposal sites, or those who might be endangered by transportation accidents. Not only transportation of spent nuclear fuel, but potentially reactors loaded with fuel, since the rulemaking would allow "... transporting fueled reactors to deployment sites (loaded with unirradiated or irradiated fuel) ...".

The government agencies whose job it should be to ensure public safety are instead being tasked to expedite licensing of new reactors and promote the use of nuclear power. These overreaching executive orders contradict the NRC's charter and thus violate existing federal law, and probably international agreements as well.

According to the proposed rulemaking document: "E.O. 14300 directs the NRC to reach a final decision on an application to construct and operate a new reactor of any type within 18 months." If the intent was to speed up the rejection process and thus reduce investments in bad technology, this would make sense. However, the rule is clearly written with the intent of pushing acceptance based on a firm deadline, regardless of what might get overlooked.

In reality, speed is the antithesis of safety. And yet, the proposed rule would allow any company requesting a license to shortcut safety regulations for the sake of expediency. For example, instead of a rule that would "... impose quality assurance requirements under the existing regulations ..." the new rule would "... allow the applicant to choose an industry approved quality assurance program ...". Self-regulation DOES NOT WORK! That's why the NRC was created in the first place: America tried self-regulation with the Atomic Energy Commission (AEC) and it failed miserably.

Lastly, although that is never explicitly stated, the new ruling appears to assume AI will be used for many control room tasks, with phrases like these: "... autonomous performance of operations and safety functions." and "... the expectation that the role of operators would be reduced for microreactors ...".

AI has yet to be found trustworthy, free of hallucinations, or right all the time. It may be better than humans at all these things some day, but nuclear reactors already require super-human efforts to operate — and that is why they have failed, sometimes catastrophically, numerous times in the past. There is no reason to believe that AI, or better-trained humans, or better-selected control room operators, or anything else, can ever guarantee the level of perfection needed to safely operate ANY nuclear reactor under all possible, probable, or expected conditions.

Sharon & Ace Hoffman, Carlsbad, California USA

* FAFO: Most fuel will probably be this type in the long run

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Contact information for the author of this newsletter:

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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

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One EMP (Electro-Magnetic Pulse) from a single nuclear explosion could destroy the whole world...and you wouldn't even know it happened (at first).

Imagine this:

You live in New York, or maybe Los Angeles. Boston or San Francisco. Chicago or Houston. Seattle or Miami. It won't matter.

You're toiling away at life, maybe at work or at home, sitting at your computer, or watching a game on your 4K TV, when the power goes out. Sudden silence.

Of course, you know that happens sometimes. But off in the distance you hear a crash and wonder: "Did the traffic lights fail too? That's rare, but I suppose it can happen."

But quickly you notice something else: Your UPS (Uninterruptible Power Supply) isn't beeping. Not only did it fail you just when it was supposed to protect your system, but normally it would be beeping now, and it's not.

The power isn't coming back on, and you don't hear sirens for whatever accident you think you might have heard... nothing. Just silence.

You're wondering what could have happened.

What you don't know is that it's happening throughout the entire continent: All of America, Canada, and Mexico are completely powerless.

Someone has exploded a nuclear device above the atmosphere. Approximately above Kansas, more than a thousand miles away from you. So of course you don't know this. Even a lot of the people in Kansas don't know it. There was no pressure wave. No mushroom cloud. There was a burst of light that quickly faded but not everyone (the whole of North America) was close enough to see it. You didn't see it. No one in your state saw it.

It was an EMP (Electro-Magnetic Pulse) from the nuclear explosion. By exploding it where they did, its effect was able to spread across a vast area.

No cities (or people) were turned to dust. No concussive shock wave was knocking over buildings, sending cars and people flying through the air. None of that happened anywhere, and yet...

...And yet this will soon become the biggest catastrophe in history, roughly equivalent to the wiping out of the dinosaurs from an asteroid impact 65 million years ago, only this time the dominant species being wiped out is us, and the cause... is also us.

But those moments haven't come yet. The nuclear reactors will quickly overheat and melt down, and the water in their spent fuel pools would soon evaporate, causing the zirconium fuel cladding to self-ignite, perhaps even causing a criticality event when the uranium fuel pellets gather as they drop to the bottom of the dry, on-fire spent fuel pool.

You look at your phone. To your surprise, it still seems to work, but it can't connect to anything, and... you smell smoke.

Something's caught fire somewhere, but again, no sirens. You try to use your phone some more, but it can't connect. People are coming out of their houses. You hear glass breaking. People can't get out of their cars any other way. The smell of smoke gets worse.

Science fiction? Or scientific fact? Could one nuclear bomb do all that?

A complete study was done years ago. It's still classified, but there's every reason to believe this an utterly realistic scenario. Not only that, but any nuclear-tipped missile that reaches the upper atmosphere could cause an EMP that could devastate an area hundreds or thousands of miles wide if it detonates prematurely, or if that's what someone actually wants to do with it, or if it's designed so that if someone tries to destroy it in-flight (after it leaves the launch area) it will blow up — and someone tries.

For a society running on energy, this would be bad enough. For one running on nuclear energy this would be fatal, because the backup generators would not work, the control systems would not work, MAYBE some of the automated SCRAM equipment would work (if they're based on always-on electromagnets and gravity or springs if the power fails)... but that would only provide a temporary solution. Without circulating water, it's a lost cause. The reactor staff runs — literally, because their cars won't start. Some are stuck behind electronic doors and gates that won't open.

Most of the military would be incapable of moving, other than on foot with what they can carry. The most sophisticated long-range bombers and a few other things are theoretically protected from an EMP, but full testing has never been done, because atmospheric testing of nuclear weapons was prohibited when this writer was six years old — 64 years ago. Delicate electronics have come a long way since then and are in every major weapons system — including the triggers in the nuclear warheads.

The runway lights, maintenance hanger lights and doors, testing equipment, lifts, power tools... would all be unavailable, and power itself — would never return. (Oddly enough, a Ford Model A might still run -- if it had gas!)

The tissue of living organisms would not be affected by the EMP, but it cannot be said that absolutely no one would be killed by the EMP burst itself. If you have a pacemaker or were being operated on at the time — those people might not make it.

Which might mean they're the lucky ones, because things will keep getting worse.

As the power grid fails to come on, water cannot be pumped, fires cannot be put out, and soon, food spoils and thirst, hunger and desperation drive those with weapons to start to overpower those without. But even before that, the nuclear power plants would be spewing toxic radioactive gasses and people living downwind would be getting violently ill, not recovering, their insides melting away, turning to mush, like Alexander Litvinenko, after he was poisoned by Putin's henchmen with Polonium-210.

Few people, if any, would know why people were getting so sick. No one would be able to do anything, or know where to go to get away from whatever is making everyone so sick.

Wandering gangs would grab whatever they can, kill whoever they want, and it would never, ever get better.

One bomb. One EMP. One entire continent, with over 100 nuclear reactors destroyed (94 in America, 19 in Canada and two in Mexico).

The rest of the planet would not get away unscathed. Not with over 100 nuclear reactors melting down, their fuel pools catching fire, and if any airplanes fell out of the sky onto a nuclear waste dump (dry storage system) that too would probably be on fire too.

The genetic code of every living thing would soon be affected, and within a few decades, there would be few large living things left on earth.

Is there a solution? A way to stop this from being possible? Or do we just have to hope nobody does it?

Of course it can be prevented, but the solution is not found in any non-proliferation TREATY. Treaties can be broken. In reality, this tragic possibility can only be prevented by all sides dismantling anything that could launch such an attack. Dismantling the nuclear warheads AND the nuclear reactors.

And we still won't have solved the problem of what to do with the waste, but at the very least, we should stop making more.

Society needs to shut down the nuclear reactors and stop making the primary ingredient for nuclear weapons (Plutonium-239), and the primary (most vulnerable) TARGET for nuclear weapons (nuclear reactors and nuclear waste dumps).

Ace Hoffman, Carlsbad, California USA

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Notes:

Fortunately, the prolific and very talented author Annie Jacobsen has researched the topic of EMPs fairly thoroughly and her book Nuclear War: A Scenario (Copyright © 2024) (our review is online here) presents some of this information (although all of it was fairly well-known long before her book came out).

From Nuclear War: A Scenario, pages 154-155: "Richard Garwin wrote the first paper on nuclear EMP in 1954, at Los Alamos (its findings are classified)." In 1962, after Starfish Prime (a high-altitude nuclear test blast), "it became clear that an EMP weapon exploded at high altitudes has the capability of permanently destroying large-scale infrastructure on the ground." Also on page 155, Jacobsen mentions a former CIA analyst telling about a Russian nuclear EMP test blast that destroyed "all manner of electronics within an enormous footprint extending hundreds of miles." Jacobsen also mentions that no one really knows if the EMP-protection for Marine One will really work.

On page 254, Jacobsen refers to a U.S. EMP Commission which has — for decades — "asserted that a high-altitude EMP attack will damage or destroy America's entire block power grid."

On pages 265 and 266, Jacobsen describes how every electronic controller in every factory would fail. Valves for gas pipelines would "rupture and explode." Planes would fall out of the sky... one disaster after another would begin to occur.

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Contact information for the author of this newsletter:

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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

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Southern California Edison Community Engagement Panel: Nuclear Waste Challenge (80 years on...)

To Whom It May Concern, Southern California Edison Community Engagement Panel:

I'm tired of the lies of the nuclear industry, and few lies are worse than the lie that the nuclear waste problem is solvable.

Not only have we been told for 80 years it's solvable, but that it can be solved quickly, efficiently, a dozen different ways, at a reasonable cost, and we can start right away, and Finland is already doing this, and France is already doing that, and everybody has a plan...

None of that is realistic in any way.

So why are YOU hosting a discussion about something that's impossible? And why pretend you're here to help us, or enlist our help in solving a problem we didn't make and didn't want? We have already been promised solutions a million times, and all you've got to offer us this time is moving the waste elsewhere and making it someone else's problem.

Where it's going to go isn't our problem. After all, we were PROMISED the waste would be removed as soon as it had cooled enough to be moved — about five years, we were told. So why are we — the local public — being tasked with figuring out how YOU are going to get rid of it? That's YOUR job, not ours! Go find a place to put the waste, if you won't neutralize it first (see below for a link to a description of the (patented) neutralization process, and its many advantages (along with its various disadvantages, similar to every other nuclear waste "solution")).

But of course, you're here because you can't find ANY place to take the waste. No one wants what you're selling. Despite the average American having only a sixth-grade reading level, no one's left on earth who is that ignorant.

But that's your problem, not ours: Go present your case to whoever you want to take the waste! Offer them a deal. Then a better deal. Find out how much nuclear waste they'll take, and under what conditions they'll accept it. Study their claim that they have a "safe" place for it, ask how it will all be safely transported. Make sure the destination location knows A LOT about how dangerous this "waste" they're accepting is, what a "criticality event" is, what a zirconium fire is and what might start one. Be sure they know how long the spent fuel will be toxic for. Let them know about the proliferation risks if it's ever stolen.

Remind them that Yucca Mountain wasn't ever going to be large enough to take all the nation's waste because we KEEP MAKING MORE and we've long passed it's planned capacity.

And if we don't stop making more, the whole process of finding a "safe" location will have to be repeated ad nauseam.

If you want to SOLVE the waste problem, you'll need to do two things, at a minimum:

First, spend a lot more money: On more proper containment, more proper transport systems, and of course, a final resting place for this mess. This is never going to be cheap, but it's never going to get any cheaper.

Second, to actually SOLVE the waste problem in any meaningful way, the industry has to stop making the problem worse! It must stop making more spent fuel! Because there's no way ANY nuclear power plant can profitably pay for its own waste storage for the centuries (MINIMUM) that the waste will exist on earth, in spent fuel pools, then in canisters, out in the open, before we permanently store it somewhere, or "burn" it (a misnomer for the filthy and expensive process of extracting fissile material for future use), and/or banish it forever to a tunnel deep in the earth. And hope for the best.

As if we — humans — have ever been able to do any thing that will last forever! Certainly a pyramid or dome-shaped structure around **each** dry canister is a real option for temporary, guarded, far safer storage — but it won't be cheap because slavery (as was used in Egypt to build the Pyramids) was abolished in America long ago, and wage slavery should be, and the only solutions the nuclear industry will accept MUST be cheap, or it will be clear to everyone what a Faustian Bargain we've made with the nuclear industry.

The entire nuclear industry should be admitting the truth, instead of bringing in "experts" who can't transport the waste safely: The standards do not require protection from bridge or tunnel collapses (fall distances and/or crush strengths could easily be exceeded in real-world accidents); the Baltimore Tunnel Fire far exceeded canister protection requirements (time and temperature), but fortunately spent nuclear fuel wasn't being transported that day.

And let's not talk about sabotage or terrorism or war, even though those are all real possibilities. Even though — oh look — another reactor in Ukraine has been attacked... and America itself is in the midst of an illegal and undeclared war... but we're supposed to believe it can't happen here? It won't come to our shores? Never in a million years? Have we all forgotten 9-11? We are ignoring drone swarms now, too!

The CEP panel should be admitting the truth, instead of bringing in "experts" who can't store the spent fuel safely in an earthquake zone a few dozen yards from the Pacific Ocean, where it's susceptible to huge tsunami's from nearby undersea canyon collapses — the canisters are required to withstand submersion only to about 50 feet, though sometimes I've heard 70 or 80 feet, which is still not nearly enough. And the requirement doesn't include protection from the added weight of debris or ship hulls crushing the canisters and making them unreachable at the same time.

You should be admitting the truth, instead of bringing in "experts" who can't admit that the cost of "proper" canisters would exceed the cost of all the gold on earth — because it just so happens that stainless steel isn't that good a containment, and surrounding it in copper is only somewhat better, but surrounding it in multiple layers of each, with additional layers of gold would actually be even better, because the canisters would last longer.

Too expensive? Of course it is! And an even bigger problem is that there is far more nuclear waste in the USA than all the gold ever extracted (by volume, or by weight). Iridium might be even better for containment, but there's even less of that — and it's far more expensive than gold.

And that's really a major problem: The nuclear industry CANNOT operate at a cost-effective rate, and so it has to be given a break on insurance if anything goes wrong — Price-Anderson — and has needed TRILLIONS in federal funding and tax breaks just to come close to the price of carbon-based fuel sources, but even that can't TOUCH the low price of true green energy: Wind, solar, wave, tide, battery storage, hot sand energy storage, lifted weight energy storage...

And the biggest gift to the nuclear industry was that the FEDERAL GOVERNMENT would take the waste. They won't because they can't. So America needs to stop making more.

Done properly, household electrical energy should be FREE most of the day, every day (as it is already in some parts of the world, due to the use of solar power).

Nuclear can never compete on safety, security, cost, environment... nothing. It's lousy "baseload" too because it sometimes just goes down for no good reason, for long lengths of time. Real baseload comes from multiple small sources. Everyone knows that except the nuclear industry!

So why can't the CEP throw up its arms (if it has a spine) and recommend to Diablo Canyon's operators (PG&E) to shut down? Why is SoCalEd still invested in Palo Verde? And since they ARE a part owner, why can't our waste can be shipped there? Why not this very day?

Why aren't these so-called "experts" doing their song-and-dance around Phoenix and Tucson, telling them how great it would be, and how safe it would be, if they would add San Onofre's waste to Palo Verde's existing waste (and to all the waste Palo Verde will make in the future if they don't shut down those reactors)?

PVNPP probably would have only one guard (or maybe just a robot) for all the waste, so it will save everybody money, right? So why aren't you, the CEP, pushing SCE to do that, so we, here, can be done with this mess, this risk, this liability?

Is it because doing so would admit failure? Or is it because SCE wants to put SM[N]Rs at San Onofre?

Or is it because it would be very unpopular in Arizona? (I have relatives in Arizona; I can assure you not everyone will like the idea.) But you assure US it's safe, so why not consolidate it? That's the IDEA of "CIS" so why not start by moving SanO's waste to PVNPP? Prove to the nation it can be done! Prove it's safe! Prove all the communities along the way will be happy to have 123 canisters of highly toxic crud pass near their homes, under heavy guard, in highly obvious vehicles, at any hour of the day and night, for several years.

Why come here and bother us? We've already agreed you should get rid of it, AS PROMISED. Allison Macfarlane had her chance to call for universal closure of nuclear reactors because of any of thousands of unsolvable problems. She has nothing to offer local San Onofre residents but more empty promises.

Ace Hoffman, Carlsbad, California USA (images added to the online version June 2026)

Four related essays:

Spent fuel neutralization: What it is and why it's the best solution:

https://acehoffman.blogspot.com/2017/11/what-is-spent-nuclear-fuel.html

Nuclear waste mismanagement: The view through the years:

https://acehoffman.blogspot.com/2017/10/nuclear-waste-management-view-through.html

We will haunt humanity forever with the nuclear waste we produce today:

https://acehoffman.blogspot.com/2026/03/we-will-haunt-humanity-forever-with.html

42 Reasons you can't disentangle nuclear reactors, nuclear weapons, and nuclear waste:

https://acehoffman.blogspot.com/2025/11/42-reasons-you-cant-disentangle-nuclear.html

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Dear Ace,

When I was a new activist, an innocent artist looking for solutions, I thought of entombing reactors and spent fuel in pyramids. I created an art piece called The Mountain Builders for the 1990 Earth Factory art show mapping all the U.S. reactors and their water sources. (That was when I learned Palo Verde didn't have a water source.) I created a giveaway souvenir post card with language from future peoples who didn't understand the pyramids or their locations or the symbols of skulls and crossbones and atomic orbits and thought a simple people had built them to scare aware aliens from outer space. People visited them on pilgrimages and admired their majesty and mystery.

Somehow I met Lake Barrett who is featured in Meltdown: Three Mile Island. I believe it was when the League of Women Voters nuclear waste project came to Atlanta. Dixie Lee Ray was there! I told Lake Barrett my idea and he said it was an idea that had been voiced in serious circles!

Who doesn't love a good pyramid!!

Glenn Carroll
Coordinator
Nuclear Watch South
Atlanta, GA
www.nonukesyall.org

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Contact information for the author of this newsletter:

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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

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