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
###
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
No comments:
Post a Comment
Comments should be in good taste and include the commentator's full name and affiliation.