Last day to comment is TODAY (Monday, October 19, 2026)!
Submit comments here: https://www.regulations.gov/document/NRC-2022-0052-0007
Our comment (shown below) was submitted and has this Comment Tracking Number from the NRC: mvf-gwfz-bthx
Re: Docket ID NRC-2022-0052
October 19, 2026
We oppose the plan to open a new evaluation period for the trial Regulatory Guide (RG): Acceptability of Probabilistic Risk Assessment (PRA) Results for Non-Light Water Reactor (non-LWR) Risk-Informed Activities.
The original two-year trial of this RG ended in May 2024, and the NRC plans to reopen it for an additional three years. The NRC does not explain what data they collected during the initial evaluation, or what additional data will be available as a result of a new/extended evaluation. "Non-LWR" refers to reactor designs that have only been built experimentally, such as sodium-cooled reactors. The trial RG ignores the unique risks of these untested reactor designs.
The plan to reopen the evaluation period also ignores the misuse of PRAs for existing reactor licensing rules. According to the NRC a PRA is: "A systematic method for assessing three questions that the NRC uses to define 'risk'. These questions consider (1) what can go wrong, (2) how likely it is, and (3) what its consequences might be." (Source: https://www.nrc.gov/education-regulatory-research/glossary/probabilistic-risk-assessment-pra). According to this definition, PRAs should help a society evaluate the consequences of events that are inevitable but unpredictable (such as 100-year floods) as well as the consequences of events that are extremely rare but still inevitable and unpredictable such as a major earthquake. Considering the history of nuclear reactors worldwide, meltdowns occur on average at least once every decade, globally. Preventing extremely unlikely events has never been possible; properly predicting their likelihood, as well as their outcomes, is a vital part of any PRA.
Instead, the nuclear industry has traditionally used PRAs to define the inevitable as if it were so unlikely that the consequences don't even have to be considered. However, the opposite is true -- the release of nuclear waste is virtually inevitable because no civilization has ever protected living things from a hazard it creates that remains dangerous for hundreds of millennia. Whether by war, neglect, mismanagement, careless mistakes, intentional or unintentional operator actions, intentional or accidental airplane strikes, AI-based infiltration/cyber attacks, earthquakes, tsunamis, fires, space debris, etc. catastrophic meltdowns can and WILL happen. There is no "short history" of strange and obscure near-misses in the nuclear field. Instead, there are entire books that discuss them. Bennett Ramberg's Nuclear Power Plants as Weapons for the Enemy is one of them. Many other books have long lists of such "rare and unlikely" events — that have already happened.
In addition, the hazards of such "accidental" (but more or less inevitable over time) releases are far greater than the regulations acknowledge (otherwise there would be NO releases allowed from operating reactors and they would all be forced to shut down immediately). PRAs that ignore or misuse these facts are already being used to license existing reactor designs and this misuse should not be extended to new reactor designs.
Thank you for your attention in this matter.
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
Ace Hoffman's Nuclear Failures Reports
Ace has studied nuclear issues since the 1960s. This site was NOT written with AI! (A January 2025 conversation with a chatbot is the ONLY exception.)
Monday, October 19, 2026
Monday, October 12, 2026
The Jellyfish and the Scarecrow: But how can you think without a brain?
Does AI have a brain?
No.
Not "I don't think so." Just "No."
And renaming it Super-Intelligence doesn't help. (I've always preferred calling it "Imitation Intelligence" as long-time readers know).
AI is good at imitating intelligence. So are some people, especially those with good memories.
But remembering a fact — such as that: "correlation does not prove causation" doesn't mean you apply it properly in all circumstances. Memorizing facts isn't intelligence.
AI doesn't even do that, though — it sorts through the quips and blurbs it's found in the past and applies the ones that statistically seems most appropriate, in the word patterns used by the intended recipient. The main goal of most AIs is to keep you engaged, and to do that, they have to please you. They don't have to be honest, or helpful, or moral. If its goal is to get you to come back time and again (so it can gather information about you or information that you have that it wants), you have to like it.
A few days ago Ukraine took out a major portion of Russia's AI Data Centers, and people around the world noticed a sudden drop in all sorts of attacks: Flaming comments from supposed patriots in support of traitorous behavior being the most noticeable for many people.
For the author of this blog, it was a sudden drop, over a matter of hours, to about 1/30th of the recent traffic at this web site (see image of the drop that approximately matches the timing of Ukraine's successful attacks on Russia's data centers).
Beginning about three months ago, traffic here had been growing tremendously: from an average of about 20k visits a month (according to Google's statistics) to a whopping 153,000+ this month -- and it's only the 11th day of the month! But about 30 hours ago, the "deluge" ended over a three-hour period. Visits have dropped back to about a thousand a day, which is exciting and treasured to see — but 52,568 in one day didn't seem real...because it wasn't (but it happened (according to Google's stats) on October 8, 2026).
Why would Russia be interested in this web site?
Perhaps because ROSATOM is just about the most corrupt corporation on the planet (as I wrote in 2018) and is pushing nuclear power all around the world (According the World Nuclear News Daily (WNN): "The first unit at Bangladesh's Rooppur Nuclear Power Plant achieved criticality - a self-sustaining nuclear reaction - at 15:34 on Sunday, 11 October [2026]"). Russia is forcing countries to be tied financially to Russia for decades to come, and in return Russia gets free nuclear weapons source material (mainly the plutonium (Pu-239) every reactor produces, as well as the Uranium (U-235) that's left in the "spent" fuel (only a fraction is actually "burned up" during use in a reactor)).
There may be other reasons: Who knows what evil lurks in the hearts of man (or machine)?
It's important to recognize Russia's influence all over the world. For example, besides Bangladesh, Russia is pushing nuclear power in many other countries, which may explain this next chart, showing the total visits from the top 19 countries for October 11, 2026. In the last week of the "deluge" the United States was as low as 8th; well below normal.
There are several "take-aways" from this event. Most importantly, watch out for propaganda!!! A lot of what Russia publishes is completely false. Do they plan to make a copy of my web site but with misleading statements? Other people have reported huge drops in fake-name, fake-photo, fake "patriots" attacking them on Twitter and/or Bluesky and other platforms, claiming to be proud American Trump supporters, which is a conflicting position to be in, to say the least!
There's no knowing why I'd been subject to a deluge of visits. It's interesting that Google seems to distinguish between these visits and other types of visits: One is recorded as shown, the other is indicated by the actual counts for individual essays, a recent example is posted on the left. Those have continued to climb, but nothing like by 52,568 total in one day for the 480 or so essays I've posted here: That would be an average of over 100 new visits to every essay just on October 8, 2026! As shown here are the current top 20 essays and their most recent 24-totals (after the "deluge").
One last thing: For any real Russians visiting (2 in the last 24 hours): Welcome! Let's work together to make the world a safer, fairer, more equal and totally non-nuclear place!
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
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, October 11, 2026
Comments Due 20261013 (THIS TUESDAY!) on NRC-2025-1204-0004: In Situ Recovery Monitoring and Decommissioning Timelines
Post comments here:https://www.regulations.gov/document/NRC-2025-1204-0004
Re: Docket ID NRC–2025–1204
Our comment ID for the comment below is: mv4-c8wi-bawt
We strongly oppose the rulemaking proposed in NRC–2025–1204, In Situ Recovery Monitoring and Decommissioning Timeliness. In the context of this proposed rule, In Situ Recovery (ISR) refers to a process for extracting uranium via chemical leaching, which liquefies a portion of the rock, allowing the uranium-bearing liquid to be pumped to the surface for further processing. ISR uranium processing has been used commercially since the late 1970s and has been the primary method of uranium extraction in the U.S. since the 1990s. ISR uranium processing is unnecessary and unsafe. The process inevitably contaminates groundwater, which cannot be returned to its previous state -- whether the [contaminant] is a leaching agent that was left behind or radioactive isotopes that were released but not extracted during the leaching process. Groundwater travels through pathways that are not accurately mapped which means that contamination from uranium extraction cannot be guaranteed to be restricted to the "production unit" (e.g., the ISR site), which is the only area that requires even theoretical cleanup. The proposed rule also limits the length of groundwater monitoring in the production site to just one year. Groundwater at each ISR location will behave differently due to natural variations [in] water chemistry and geology (e.g., tiny fissures in the surrounding rock). Variations in rainfall or irrigation runoff can also impact both the volume and chemistry of groundwater, so even at a single site, the behavior of the groundwater may be different at different times. Groundwater can remain in an aquifer for tens of thousands of years, and there are places in the United States where some of today's drinking water comes from glaciers that melted at the end of the last ice age. Neither existing NRC regulations nor the proposed new regulations directly address contamination of groundwater beyond the production site. Instead they rely on criteria such as " ... the construction of wells, the design of ISR wellfields, and groundwater monitoring [within the production site] ... " to protect the aquifers. The net result of ISR uranium processing is potential contamination of drinking water for millions of people for millions of years — for something nobody needs. The United States does not need more uranium, because the United States does not need more nuclear weapons or nuclear reactors. No uranium is needed for refueling, because all the existing reactors should be shut down. Nobody knows what to do with the nuclear waste that already exists, which will continue to be hazardous to all living things for hundreds of millennia. Both the operating reactors and the waste are also weapons proliferation risks as well as targets for enemy or terrorist attacks. The proposed rulemaking does not even protect the environment from the immediate results of ISR uranium processing. The rule would allow companies who want to profit from ISR uranium processing to simply request an exemption if cleaning up the production site to the required standard is too difficult (i.e., too expensive). Before any ISR uranium processing project is licensed, the NRC and the EPA should define consequences for failure to clean up the production site , and require the company requesting a license to provide proof that clean-up is possible — and that they can pay for it even if they go bust for any reason. (Such proof is impossible to provide for the reasons explained above, and for that reason alone the NRC should not continue to license ISR uranium processing.) This rulemaking is titled In Situ Recovery Monitoring and Decommissioning Timeliness because in addition to the proposed changes to licensing for ISR uranium processing, the same rule makes substantive changes to an unrelated part of NRC regulations: decommissioning timelines for nuclear reactors. Including these two different topics within the same proposed rulemaking, and allowing only a 30-day public comment period without any scheduled public meetings makes it extremely difficult for citizens, public-interest organizations, government organizations, and tribal stakeholders to evaluate and comment on the proposed rulemaking. Although some of the proposed changes have been discussed for at least five years as shown by the July 2020 EPA-NRC Memorandum of Understanding on ISR Rulemaking cited in this rulemaking, nevertheless the information provided for public comment is far from complete. Before any further consideration of this rule, the NRC should provide the additional information and extend the public comment period as requested by the New Mexico Dept. of Justice. We incorporate by reference and adopt as our own the entirety of the comments submitted by the following parties: Lynda Williams: https://www.regulations.gov/comment/NRC-2025-1204-0006 (tracking #: mtx-h1f9-88d4) New Mexico Dept. of Justice: https://www.regulations.gov/comment/NRC-2025-1204-0014 (tracking #: mu5-y1qn-da05)
Submitted by Sharon and Ace Hoffman, Carlsbad, California USA (One word has been corrected in the online version in [brackets] and another added [also in brackets]). (A corrected version was submitted on Tuesday; tracking #: mv7-7h4r-6811.)
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
We strongly oppose the rulemaking proposed in NRC–2025–1204, In Situ Recovery Monitoring and Decommissioning Timeliness. In the context of this proposed rule, In Situ Recovery (ISR) refers to a process for extracting uranium via chemical leaching, which liquefies a portion of the rock, allowing the uranium-bearing liquid to be pumped to the surface for further processing. ISR uranium processing has been used commercially since the late 1970s and has been the primary method of uranium extraction in the U.S. since the 1990s. ISR uranium processing is unnecessary and unsafe. The process inevitably contaminates groundwater, which cannot be returned to its previous state -- whether the [contaminant] is a leaching agent that was left behind or radioactive isotopes that were released but not extracted during the leaching process. Groundwater travels through pathways that are not accurately mapped which means that contamination from uranium extraction cannot be guaranteed to be restricted to the "production unit" (e.g., the ISR site), which is the only area that requires even theoretical cleanup. The proposed rule also limits the length of groundwater monitoring in the production site to just one year. Groundwater at each ISR location will behave differently due to natural variations [in] water chemistry and geology (e.g., tiny fissures in the surrounding rock). Variations in rainfall or irrigation runoff can also impact both the volume and chemistry of groundwater, so even at a single site, the behavior of the groundwater may be different at different times. Groundwater can remain in an aquifer for tens of thousands of years, and there are places in the United States where some of today's drinking water comes from glaciers that melted at the end of the last ice age. Neither existing NRC regulations nor the proposed new regulations directly address contamination of groundwater beyond the production site. Instead they rely on criteria such as " ... the construction of wells, the design of ISR wellfields, and groundwater monitoring [within the production site] ... " to protect the aquifers. The net result of ISR uranium processing is potential contamination of drinking water for millions of people for millions of years — for something nobody needs. The United States does not need more uranium, because the United States does not need more nuclear weapons or nuclear reactors. No uranium is needed for refueling, because all the existing reactors should be shut down. Nobody knows what to do with the nuclear waste that already exists, which will continue to be hazardous to all living things for hundreds of millennia. Both the operating reactors and the waste are also weapons proliferation risks as well as targets for enemy or terrorist attacks. The proposed rulemaking does not even protect the environment from the immediate results of ISR uranium processing. The rule would allow companies who want to profit from ISR uranium processing to simply request an exemption if cleaning up the production site to the required standard is too difficult (i.e., too expensive). Before any ISR uranium processing project is licensed, the NRC and the EPA should define consequences for failure to clean up the production site , and require the company requesting a license to provide proof that clean-up is possible — and that they can pay for it even if they go bust for any reason. (Such proof is impossible to provide for the reasons explained above, and for that reason alone the NRC should not continue to license ISR uranium processing.) This rulemaking is titled In Situ Recovery Monitoring and Decommissioning Timeliness because in addition to the proposed changes to licensing for ISR uranium processing, the same rule makes substantive changes to an unrelated part of NRC regulations: decommissioning timelines for nuclear reactors. Including these two different topics within the same proposed rulemaking, and allowing only a 30-day public comment period without any scheduled public meetings makes it extremely difficult for citizens, public-interest organizations, government organizations, and tribal stakeholders to evaluate and comment on the proposed rulemaking. Although some of the proposed changes have been discussed for at least five years as shown by the July 2020 EPA-NRC Memorandum of Understanding on ISR Rulemaking cited in this rulemaking, nevertheless the information provided for public comment is far from complete. Before any further consideration of this rule, the NRC should provide the additional information and extend the public comment period as requested by the New Mexico Dept. of Justice. We incorporate by reference and adopt as our own the entirety of the comments submitted by the following parties: Lynda Williams: https://www.regulations.gov/comment/NRC-2025-1204-0006 (tracking #: mtx-h1f9-88d4) New Mexico Dept. of Justice: https://www.regulations.gov/comment/NRC-2025-1204-0014 (tracking #: mu5-y1qn-da05)
Submitted by Sharon and Ace Hoffman, Carlsbad, California USA (One word has been corrected in the online version in [brackets] and another added [also in brackets]). (A corrected version was submitted on Tuesday; tracking #: mv7-7h4r-6811.)
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
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