Post comments here:
https://www.regulations.gov/document/NRC-2026-2806-0001
Identify comments with: Docket ID NRC-2026-2806
Our comment (posted Sept. 24, 2026) has NRC Comment Tracking Number: mug-cuvr-z1vx (yes, they call that a "number")
The final version of the rule, which contains far more detail than the proposed rule, and will automatically be finalized on November 9, 2026 unless " ... the NRC receives any significant adverse comment ..." is available here:
https://www.regulations.gov/document/NRC-2026-2806-0002
We oppose implementing the proposed rule covered by docket id: NRC-2026-2806. In particular we object to moving this proposed rule to a final rule without a full explanation, disclosure, and understanding of the potential environmental impacts.
According to the Federal Registry publication of this proposed rule, the NRC plans to approve a design change for a particular spent fuel storage cask design: TN Americas, LLC StandardizedNUHOMS® Horizontal Modular Storage System. More specifically, the rule allows an " ... improved basket design using staggered plates ...". Whether this design offers more protection or less to the public and the environment is not specified and there is no "plain language" (as required by law) that explains exactly what is changing.
The NRC says that the change " ... does not reflect a significant change in design or fabrication of the cask." This statement leads directly to the conclusion that the rule change entails: " ... no significant increase in the individual or cumulative radiation exposures, and no significant increase in the potential for, or consequences from, radiological accidents." Without a definition of "significant" and a clear explanation of the tradeoffs that led to this requested design change, the public cannot evaluate the proposed rule. For example, ML26103A252 (which describes information about the proposed new design) includes the phrase: " ... a unique design and a higher heat load ...". This certainly sounds significant. If a "higher heat load" is NOT significant, why mention it? More to the point, in what way would that be insignificant and yet be the whole point of the "unique design"? (ML26103A252 is available here:
https://www.nrc.gov/docs/ML2610/ML26103A252.pdf)
Equally important, the design is a moving target. Less than two years after the original submission (November 5, 2024) the design of the system is being revised. What was wrong with the previous design? Were there engineering flaws, or did the applicant simply find a way to cut costs without (according to the applicant) impacting safety? Similarly, somewhere in the many pages of technical jargon we find that the " ... applicant requested to withdraw Change No. 2 during the process of the review ...". Why? How much of the evaluation was completed before Change No. 2 was withdrawn? How much time did the NRC waste on "Change No. 2"? What was the cost to the public of uselessly evaluating Change No. 2?
This proposed rule should be rejected because neither the applicant nor the NRC has explicitly addressed whether this design change would improve safety which should be the primary criteria for a spent-fuel cask design. Rather, it appears that it will increase RISK by allowing an increased thermal load, which will have a corresponding increased radioactivity load. In fact, why is it referred to as an higher "heat" load when that is a direct result of an increased radioactivity load?
Once we stop producing more nuclear waste (since nobody has a solution for storing it for the millennia it remains dangerous), it might be worthwhile to consider these design changes in light of the need for eternal storage of nuclear waste. However, the argument that it will be more expensive for licensees to prepare exemption requests and for the NRC to review them than to reject the design change is disingenuous.
We incorporate by reference and adopt as our own the entirety of the comments submitted by Steven Singleton (
https://www.regulations.gov/comment/NRC-2026-2806-0003 tracking #: mtw-cjsu-atw9)
Ace & Sharon 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
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