We strongly oppose the proposed change described in NRC-2026-2476-0002, which would reduce many safeguards for a specific dry-cask design: Holtec's HI-STORM FW. This proposal would enable the Nuclear Regulatory Commission (NRC) to approve changes to dry-cask requirements for a particular dry-cask design as if there was no potential impact on health and safety. According to the NRC's summary, the proposed change allows design enhancements that: " ... accommodates two multipurpose canisters stored vertically ... " " ... higher allowable per-canister and per-cell heat-load limits ... " " ... reduction of minimum cooling-time requirements ... " (Specifically, Holtec is requesting that the NRC: "... Reduce MPC–44 minimum cooling time from 3 years to 1 year, and MPC–37P minimum cooling time from 1.6 years to 1 year." " ... refinement of the missile-impact analysis ... " Despite all these changes that make it possible for more radiation to escape from the dry-casks and for the casks to degrade more quickly, the NRC contends that " ... there will be no significant change in the types or amounts of any effluent released, no significant increase in the individual or cumulative radiation exposure, and no significant increase in the potential for or consequences from radiological accidents." In reality IF an accident or missile impact happens after one year of cooling versus after three years of cooling, the radiological consequences would be much more severe for the shorter time frame, "hotter" spent fuel. The rule-making proposal explicitly states that: " ... the NRC considers this action to be non-controversial ... ". Therefore, unless the NRC receives what the agency describes as " ... significant adverse comment ... " the final rule will automatically become effective on October 6, 2026. Please consider THESE comments to be SIGNIFICANT. They represent more than 100 years (combined by the two authors) of study in various related issues, including conversations with three Manhattan Project scientists and dozens, if not hundreds, of nuclear engineers, nuclear physicists, nuclear operators, nuclear plant workers, and professionals in related fields including metallurgy, radiation health physics, engineering, safety analysis, computer simulation, etc. etc.. The views presented, however, are the authors' alone. The NRC should explain the analysis by which it believes that subjecting a dry-cask to the most intense radiation for an additional one to three years does not increase the potential for, and the potential severity of, radiological accidents, especially after decades of storage during which embrittlement will continuously occur — not might occur, but will occur. Additionally, the NRC should be doing a missile-impact analysis for gravity bombs, not just small-arms impacts from Rocket-Propelled Grenades or drone-impacted explosives, or whatever they think the "most likely attack vector" is. Missile impact requirements should be based on the most damaging attack vectors (while not ignoring the most likely). Sharon and Ace Hoffman Carlsbad California USA The above comment was submitted on Aug 22, 2026 and received NRC comment tracking id: mt4-zo1t-cbak
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Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
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