We strongly oppose proposed regulation NRC-2025-1370-0001. This proposed rule aims to deregulate and minimize regulations for "materials handling" — specifically materials handling of radioactive substances. The rule would further reduce oversight of both the production of nuclear reactor fuel and the storage of spent fuel. In terms of nuclear fuel production, the proposed rule states that: "... pilot fuel lines would establish a domestic nuclear fuel supply chain for pilot reactors for non-commercial purposes." But multi-billion dollar "non-commercial purposes" can quickly become commercial purposes as the NRC continues to advocate using DOE approvals as a proxy for NRC regulations. Specifically, this rule would "... reflect the exemption for the construction and operation of pilot fuel lines authorized by the DOE for non-commercial purposes from the requirements for an NRC license." and "... streamline the NRC's licensing of potential commercial operations for such a facility." The result would be to endorse many risky fuel processing experiments, including recent Department of Energy (DOE ) plans that enable creation of plutonium-based fuel for new untested reactor designs. Thus there would be multiple layers of relaxed and/or eliminated regulations throughout the fuel chain. There are many reasons why no commercial reactor in the United States has ever used plutonium as fuel (aside from what is made within the reactor's fuel pellets as it operates). Plutonium is a weapons proliferation risk -- both for dirty bombs, and for countries or terrorists with the technology to build nuclear weapons. There is no such thing as non-weapons-grade plutonium. Plutonium is widely (and appropriately) considered to be the most hazardous, most carcinogenic, most toxic substance on earth, and it's been proven time and time again that it is impossible to work with plutonium without contaminating the environment. Facilities used to process plutonium invariably end up as Environmental Protection Agency (EPA) super-fund sites: Hanford (Washington), Rocky Flats (Colorado), Los Alamos National Laboratory (LANL) (New Mexico), Piketon (Ohio), West Valley (New York), Oak Ridge (Tennessee) and many other locations. The DOE proposal for plutonium fuel is already in progress with two companies (Oklo and Standard Nuclear) designated for "advanced negotiations" for DOE's "Surplus Plutonium Utilization Program" (source: https://www.ans.org/news/2026-06-17/article-8130/oklo-signs-mou-with-standard-nuclear-to-explore-plutonium-recycling/) Because there are many other proposed new reactor designs that DOE is promoting, funding, or investigating, there will also be many other new fuel processing proposals. All of them invariably will either create or use plutonium in some way, possibly as an initial fissionable isotope, and/or as a (perhaps unwanted, perhaps not) by-product. The proposed regulation would also make it easier to license new canister designs for spent nuclear fuel. The thousands of existing canisters at sites around the country are already disasters waiting to happen (with nowhere to go). Currently, spent fuel canisters are only licensed for 20 years whereas the spent fuel they contain will be hazardous for 100s of thousands of years. Nobody has any idea how to unload a canister which may contain spent fuel that has partially disintegrated (which would be necessary if the canisters are ever moved or replaced). Everything in this proposed rule has the potential to create ever-more nuclear waste with no possible way to manage it safely. Existing nuclear safety rules need to be strengthened, not weakened or eliminated. Sharon and Ace Hoffman, Carlsbad, California
Contact information for the author of this newsletter:
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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