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:
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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