Last day to comment is TODAY (Monday, October 19, 2026)!
Submit comments here:
https://www.regulations.gov/document/NRC-2022-0052-0007
Our comment (shown below) was submitted and has this Comment Tracking Number from the NRC: mvf-gwfz-bthx
Re: Docket ID NRC-2022-0052
October 19, 2026
We oppose the plan to open a new evaluation period for the trial Regulatory Guide (RG): Acceptability of Probabilistic Risk Assessment (PRA) Results for Non-Light Water Reactor (non-LWR) Risk-Informed Activities.
The original two-year trial of this RG ended in May 2024, and the NRC plans to reopen it for an additional three years. The NRC does not explain what data they collected during the initial evaluation, or what additional data will be available as a result of a new/extended evaluation. "Non-LWR" refers to reactor designs that have only been built experimentally, such as sodium-cooled reactors. The trial RG ignores the unique risks of these untested reactor designs.
The plan to reopen the evaluation period also ignores the misuse of PRAs for existing reactor licensing rules. According to the NRC a PRA is: "A systematic method for assessing three questions that the NRC uses to define 'risk'. These questions consider (1) what can go wrong, (2) how likely it is, and (3) what its consequences might be." (Source:
https://www.nrc.gov/education-regulatory-research/glossary/probabilistic-risk-assessment-pra). According to this definition, PRAs should help a society evaluate the consequences of events that are inevitable but unpredictable (such as 100-year floods) as well as the consequences of events that are extremely rare but still inevitable and unpredictable such as a major earthquake. Considering the history of nuclear reactors worldwide, meltdowns occur on average at least once every decade, globally. Preventing extremely unlikely events has never been possible; properly predicting their likelihood, as well as their outcomes, is a vital part of any PRA.
Instead, the nuclear industry has traditionally used PRAs to define the inevitable as if it were so unlikely that the consequences don't even have to be considered. However, the opposite is true -- the release of nuclear waste is virtually inevitable because no civilization has ever protected living things from a hazard it creates that remains dangerous for hundreds of millennia. Whether by war, neglect, mismanagement, careless mistakes, intentional or unintentional operator actions, intentional or accidental airplane strikes, AI-based infiltration/cyber attacks, earthquakes, tsunamis, fires, space debris, etc. catastrophic meltdowns can and WILL happen. There is no "short history" of strange and obscure near-misses in the nuclear field. Instead, there are entire books that discuss them. Bennett Ramberg's Nuclear Power Plants as Weapons for the Enemy is one of them. Many other books have long lists of such "rare and unlikely" events — that have already happened.
In addition, the hazards of such "accidental" (but more or less inevitable over time) releases are far greater than the regulations acknowledge (otherwise there would be NO releases allowed from operating reactors and they would all be forced to shut down immediately). PRAs that ignore or misuse these facts are already being used to license existing reactor designs and this misuse should not be extended to new reactor designs.
Thank you for your attention in this matter.
Sharon and Ace 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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