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Comments by Nuclear Energy Information Service (NEIS) Regarding NRC Proposed Rule, “Licensing Requirements for Microreactors and Other Reactors With Comparable Risk Profiles”

Comments by Nuclear Energy Information Service (NEIS)

Regarding NRC Proposed Rule, “Licensing Requirements for Microreactors and Other

Reactors With Comparable Risk Profiles”

Docket ID NRC-2025-0379; 91 Fed. Reg. 23,628 (May 1, 2026)

Submitted June 15, 2026 via Federal eRulemaking Portal

Nuclear Energy Information Service is a Chicago-based safe-energy advocacy, nuclear power watchdog environmental organization.  NEIS opposes the continued deployment of nuclear power in an energy landscape that has amply demonstrated the presence and effectiveness of cheaper, more quickly deployable, and superiorly cost-effective means of providing electric power.

NEIS hereby adopts, supports and incorporates by reference the comments submitted by the Nuclear Information and Resource Service (NIRS; dated June 15, 2026) and those of the Connecticut Department of Energy and Environmental Protection (DEEP, dated Feb. 2026), including DEEP’s request for a 45-day extension of the public comment period, unreasonably denied without justification on May 1, 2026.

In addition, NEIS provides the following comments.  Taken together, NEIS supports the contention made by other commenters that this Proposed Rulemaking should be terminated.

ADDITIONAL CONSIDERATIONS:

  • Validity of promulgating directives is challengeable:

NRC lists as its reasons for issuing this Proposed Rulemaking clauses from the ADVANCE Act, and the Presidential E.O. 14154 (90 FR 8353; January 29, 2025), titled, “Unleashing American Energy,” with an objective of unleashing “America’s affordable and reliable energy and natural resources;” as well as E.O 14300.

While the directives from the ADVANCE Act may be defensible from a regulatory, engineering and technological standpoint, those of the E.O.s are not.

For example, micro reactors and related small modular nuclear reactors (SMNRs) are not yet shown to be either “affordable (or) reliable,” largely because they do not yet exist in significant enough numbers to support this contention.  Even preliminary SMNR costs have escalated well beyond initial optimistic marketing values (e.g., NuScale/UAMPS debacle of 2023-24).  The President’s declaration of a “National Energy Emergency” has yet to be verified in any credible, reality-based manner, casting serous doubt on its validity as a basis for the changes proposed in the E.Os.

  • Numerous references to “self-regulation”:

Sections that call for “licensee-defined design and quality assurance criteria,” significant flexibility in safety classification, and reduced reliance on deterministic safety principles such as the single-failure criterion are tantamount to de facto industry self-regulation.

It would be wise to recall the dangerous history of this abdication of regulatory responsibility and accountability and its effects on the public and the environment:

  • The determination that lack of FAA regulatory oversight allowing Boeing to largely self-supervise its own design and operational procedures was responsible for two fatal crashes;
  • Acknowledgement that railroad lobbyists opposing vital train safety regulation led to the East Palestine train derailment and subsequent chemical fire;
  • Recalling that, “The … Fukushima Nuclear Power Plant accident was the result of collusion between the government, the regulators and Tepco, and the lack of governance by said parties,” according to the National Diet of Japan official report, Executive summary of The Fukushima Nuclear Accident Independent Investigation Commission, June 2012, p. 16.

The broad “… proposed rule [that] would provide flexible licensing pathways with streamlined requirements… to enable a broad spectrum of deployment models,” is likely to result in virtually no meaningful regulation at all, given the current large numbers of proposed designs, and the NRC’s and Administration’s goals of rapid deployment.

  • Significant systemic safety concerns not sufficiently addressed:

Emphasis on speed (actually haste) and genericization is an unacceptable combination that contains the elements of potential disaster.  Among these are:

  • “Microreactors and Other Reactors with Comparable Risk Profiles” exist in a world vastly different from that which ushered in the Age of Large-Scale Reactors. While the design goal of a safer reactor is highly desirable, not only does it remain a goal until actually demonstrated, it should not be the presumption on which to discard the “defense in depth” philosophy that has been the industry-proclaimed hallmark of nuclear power operations to date.  To make that egregious error of logic is a techno-hubris that places the public and environment at great risk.  Some examples of this dangerous and flawed thinking include:
  • Designs that will no longer require some form of containment, both for stationary and mobile designs
  • Termination of emergency planning zones and procedures
  • Reduced operational personnel, with the expectation they will operate multiple units; or worse, “autonomous function” operations (particularly if it is based on A/I technology of speculative performance capability for these functions).
  • Insufficiently considered safety elements:
  • Multiple designs, no matter how generic, will be placed in varied operational conditions and for varied purposes which may have impacts on operation that differ from site to site, as well as among designs;
  • Widespread dissemination of micro- or SMNRs will be operated under diverse environmental conditions, such as local geography, climate and weather, and now the increased frequency and intensity of adverse weather phenomenon – all of which must be factored into safety considerations;
  • The “Age of the Drone” and its effects on safety and security have been amply demonstrated in Ukraine and the Middle East. We submit that even undergrounding of reactors would have been of little safety value in Mariupol or Gaza.  Release of radioactive contents of micro- and SMNRs through use of drone warheads cannot be ruled out.  This is of particular concern with designs that will be running on HALEU fuel, or are sodium or helium cooled.  The increased radiologic inventory from a HALEU release, and the vulnerability and subsequent chemical hazards from a loss of the proposed coolants create unique radiologic and chemical hazards that must be designed against.  This vulnerability may be of even greater concern during the transportation of micro- and SMNR reactors to their designated final destinations.
  • This point was made abundantly clear by national security expert, Brig. Gen Chris King (retired) during a nuclear power debate held on Pacifica Radio in 2023. King’s response to the notion of numerous, mobile micro-reactors distributed all over the country was revealing:

“How do I protect and ensure the safety of those [SMNRs] from an external threat? And the more [reactors] you got, the harder it is to protect…If there’s a thousand of those scattered around, and someone’s moving them around at their own choosing, that’s a significant threat…

“That’s very, very risky from a force protection, from a national security standpoint.  It would be very difficult to achieve national security goals in that domain.”

     –Brig. General Wendell Chris King, retired, Dean Emeritus, U.S. Army Commander, General Staff College, Aug. 15, 2023, “Climate Hour”, Pacifica Radio–

4.)  Once again – the radioactive waste:

While much attention has been given to promoting these new reactor designs, we do not see comparable attention paid to the additional amounts of radioactive waste they will add to the >100,000 tons of high-level radioactive waste (HLRW) already accumulated in the U.S – with no disposal occurring to date.

Worse, the proposed use of HALEU, as well as the multiplicity of designs creates new and previously non-existent radwaste problems, both terms of the change in core inventories, and the creation of new and non-traditional forms in which the waste will occur.  All of this complicates the final disposal plans for HLRW.

For the above reasons, and particularly given the denial of an extended comment period, NEIS urges the NRC to terminate this Proposed Rulemaking process.

We thank you for your consideration.

David A. Kraft, Director

Nuclear Energy Information Service (NEIS)

3411 W. Diversey, Ste. 13

Chicago, IL  60647

(773)342-7650

neis@neis.org

 

 

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REGARDING NUCLEAR MORATORIA REPEALS…

“First, get your facts straight.  Then you can distort them as much as you want.” – Mark Twain

As a critical component of advancing the nuclear power juggernaut on an ill-informed public, for several years now pro-nuclear cheerleaders have been working feverishly to get state legislatures to repeal state-mandated moratoria on new nuclear plant construction. Read more

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SPECIAL NWTE: Crisis / Opportunity in radiation protection, featuring Mary Olson

Mary Olson will give a short update on the Executive Order 14300 (May 2025) that directs change in radiation standards at NRC, as well as new findings that constitute the front-end of a new radiation science required because of new understanding in disproportionate harm, including age, sex, and internal exposure from radioactive pollution in our air, food, and water.
DISCUSSION: How can we as a community USE the White House bad actions to create openings for rewriting what has been bad protection all along–and do with broad collaboration.

ZOOM link:

https://us02web.zoom.us/j/88089470932?pwd=gMrsMgb53M1cMba4aoKOpAYzAfhR4c.1

Recent report coauthored by Mary Olson:
Gender and Ionizing Radiation: Towards a New Research Agenda Addressing Disproportionate Harm
20 November 2024
Download for free here:
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PRESS RELEASE: Citizens Groups and Experts Warn Federal Officials that Recent Trump Executive Orders Would Decimate Standards for Radiation Exposure and Harm Public Health, Disproportionately Impacting Women and Children

PRESS RELEASE — FOR IMMEDIATE USE

As a courtesy to our safe-energy colleagues at the Generational Radiation Impact Project (GRIP), and co-signers of the referenced letter, we provide this press release Read more

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PRESS RELEASE: “Governor Pritzker, Legislators: Preserve Illinois’ Nuclear Moratorium,” Nuclear Watchdog Group Advises

PRESS RELEASE

For Immediate Use:  Monday, October 27, 2025

Contact:  David Kraft,  (773)342-7650 (o); (630)506-2864 (c);  neis@neis.org

“Governor Pritzker, Legislators: Preserve Illinois’ Nuclear Moratorium,”

Nuclear Watchdog Group Advises

CHICAGO—As the Fall Veto Session of the Illinois Legislature begins on Tuesday this week, an Illinois environmental, safe-energy advocacy organization advises:  preserve the Illinois nuclear construction moratorium. Read more

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Opinion: Repealing the nuclear moratorium would be a costly mistake for Illinois

LEGISLATURE CONFRONTS THE NUCLEAR PANDORA’S BOX  (Original title)

13 October 2025

According to the legend, an overly curious but ill-informed Pandora opened a container she was warned not to, in the process unleashing all the ills of the world upon mankind.  In fairness and her defense, one has to admit she was not informed about the contents of the container.

That seems to be the principal difference between Pandora and the Governor and Illinois Legislature today. In the Fall Session it is expected that the Legislature will be voting on the potential repeal of the 1987 nuclear power moratorium, which if it occurs, would take the lid off of construction of more nuclear reactors.

Unlike Pandora, Illinois officials are well aware of the ills of nuclear power, which are many and well known: huge construction costs and overruns; lengthy and often delayed construction times; attraction for official corruption (think Illinois, Ohio and South Carolina); continued generation of high-level radioactive wastes (HLRW) with no place for permanent disposal; difficulty operating in a market system without some form of eventual bailout; and “black-swan” but always present potential for severe nuclear accident.  It only takes one bad day at the nuclear office to turn Illinois into the Belarus of the United States.

As bad as these nuclear attributes are, the ones that the Legislature has consistently refused to address, coupled with newer issues created by the Trump Administration are equally concerning, and argue forcefully to keep Illinois’ nuclear moratorium in place:

  • Adding even more HLRW to the 11,000+ metric tons current reactors have already created (and which add ~250 tons/year), all with no place for permanent disposal;
  • Providing inadequate to non-existent “just-transitions” safeguards for reactor communities and workers to protect local tax bases, economies, and jobs from the negative economic hit that eventual reactor closure will create (as already occurred in Zion, IL);
  • Inadequately advancing preparations to operate reactors safely in an increasingly climate disrupted world, where future required water availability may be uncertain and volatile, facility-threatening weather events more severe, and conditions for power interruptions increasing in new and unexpected ways;
  • Ignoring the environmental justice implications of expanding nuclear power, from uranium mining on Indigenous lands, to siting an environmentally responsible and legally required HLRW permanent disposal facility.

While this list of neglected, unsolved nuclear problems is daunting enough, the last thing to leave today’s nuclear-Pandora’s Box is not “hope.”  It is a series of Trump Administration executive orders, issued in May, that deprioritize the Nuclear Regulatory Commission’s mission to protect the public; reduce NRC staff; call for weakening radiation standards; and require a DOGE sign-off on new reactor designs – all while quadrupling the number of U.S. reactors by 2050.  Former NRC Chairman Dr. Gregory Jaczko remarked, “President Trump’s executive order shows he is committed to further lawlessness, more nuclear accidents, and less nuclear safety.”

The 1987 Moratorium was initially enacted to protect Illinois from radioactive waste abuse.  Its presence has at least helped minimize the numerous other problems with nuclear power.  Moratorium repeal only guarantees their continuation and worsening.

Just as in the original Pandora legend, once these nuclear ills are legislatively loosed upon the world, there will be no means to put them back in the box.

Now is clearly NOT the time to be considering new reactors.

The Nuclear Moratorium repeal should be rejected.

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PRESS RELEASE: Trump Administration Gutting Regulatory Agency, Recent Nuclear Incidents, Coverup: No Time to Open Illinois for More Nuclear Power, Nuclear Watchdog Group Asserts

PRESS RELEASE

For Immediate Use:  Thursday, May 28, 2025

Contact:  David Kraft,  (773)342-7650 (o); (630)506-2864 (c);  neis@neis.org

Trump Administration Gutting Regulatory Agency, Recent Nuclear Incidents, Coverup: No Time to Open Illinois for More Nuclear Power, Nuclear Watchdog Group Asserts

CHICAGO—At a time when the Illinois Legislature and Governor Pritzker are contemplating the repeal of the Illinois nuclear power moratorium, recent real-world events argue strongly against that move, a local safe-energy advocacy organization argues.

On Friday, May 23, President Trump signed Executive Orders (E/Os) which effectively gut the regulatory power of the U.S. Nuclear Regulatory Commission (NRC) to fulfill its mandate to protect the public health, safety and environment.

On the same day it was learned that the aged Quad Cities nuclear reactor station in Illinois had experienced a manual emergency shutdown on May 19, and fire on May 22; and further, that a serious nuclear incident that occurred in March 2023 had been covered up by both the utility and the NRC.

Many experts – including two former Chairs of the NRC — have savaged Trump’s ill-advised weakening of nuclear power regulation. (see attached statement list below).  NEIS points out that the Administration’s desire to expand nuclear while slashing regulation of both aging reactors and experimental, unproven new reactors is a recipe for disaster.  The Boeing plane disasters, the East Palestine train derailment, even the Fukushima reactor disaster – all had their root cause in either de-regulation, self-regulation by industry, or government-industry collusion.

“These events show beyond a doubt that while current regulation is clearly suspect, gutting it further at a time when some Illinois legislators and officials want to expand nuclear power is an outright threat to Illinois,” maintains David Kraft, director of the 43-year old Chicago-based safe-energy advocacy/anti-nuclear organization Nuclear Energy Information Service (NEIS). “Now is simply NOT the time to repeal the nuclear moratorium,” he asserts.

Legislation SB1527 and HB3604 call for the repeal of the 1987 nuclear construction moratorium, which simply states that no new reactors will be built in Illinois until the Federal Government demonstrates that it has an operational facility to dispose of – not merely store – high-level radioactive waste (HLRW).  The U.S. has failed to build such a facility; and all HLRW remains in storage at reactor sites.  Illinois – with 11 operating and 3 shuttered/decommissioned reactors – currently stores 11,000+ tons of HLRW, more than any other state.

Illinois is powerless to enact protective legislation to compensate for the regulatory safety void created by the Trump E/Os.  The NRC retains preemptive authority on all matters pertaining to safety and security at nuclear power plants.  No state can enact regulations stricter than those created and administered by the NRC, no matter how well-intentioned or protective.  Therefore, neither Governor Pritzker nor the Legislature can enact anything that will provide additional safeguards.

The Quad Cities reactors are owned by Constellation Energy are older and the same design as those which melted down and exploded during the Fukushima disaster.  A manual “scram” – an emergency shutdown – occurred on May 19, followed by a fire on May 22.  But just before these incidents, it was revealed that according to the NRC a serious accident that involved contaminating workers with radioactive water had occurred in March 2023, but was initially covered up by the plant staff.  Three years after the fact, the NRC has still not brought any corrective action or fines to bear.

As if to punctuate this sorry operational and regulatory performance, on Tuesday May 27 the Union of Concerned Scientists (UCS) released a report titled, ‘The Terrible 13: The Worst Safety and Security Violators in the US Nuclear Power Fleet.” The Quad Cities reactors are listed in this Report.

“Governor Pritzker is reported to have said that he wants to, ‘expand the options for nuclear in the state of Illinois….But it has to be done in the right way.’” Kraft notes.

“Under these conditions, there is no ‘right way.’  The questionable level of current regulation, and now the further erosion of even that via the E/Os are not the conditions calling for more nuclear power,” Kraft states.

“Current reactors are showing signs of aging. New reactors would require greater oversight during start-up phase.  With reduced regulatory oversight, neither will be safe.  Now is clearly not the time to bring more nuclear power to Illinois,” Kraft maintains.

“One bad day at the nuclear office will reduce Illinois to becoming the Belarus of North America,” he concludes, referring to the country most heavily impacted by the 1986 Chernobyl disaster.

–30–

Nuclear Energy Information Service (NEIS) was formed in 1981 to watchdog the nuclear power industry, and to promote a renewable, non-nuclear energy future.

 

Numerous competent nuclear experts have decried the Trump Administration’s irresponsible nuclear deregulation action:

Statements by Dr. Ed Lyman, Union of Concerned Scientists:

“This push by the Trump administration to usurp much of the agency’s autonomy as they seek to fast-track the construction of nuclear plants will weaken critical, independent oversight of the U.S. nuclear industry and poses significant safety and security risks to the public,” UCS added.

Edwin Lyman, director of nuclear power safety at the UCS, said, “Simply put, the U.S. nuclear industry will fail if safety is not made a priority.”

“By fatally compromising the independence and integrity of the NRC, and by encouraging pathways for nuclear deployment that bypass the regulator entirely, the Trump administration is virtually guaranteeing that this country will see a serious accident or other radiological release that will affect the health, safety, and livelihoods of millions,” Lyman added. “Such a disaster will destroy public trust in nuclear power and cause other nations to reject U.S. nuclear technology for decades to come.”

Statements by Dr. Alison Macfarlane, former Chairwoman of the U.S. Nuclear Regulatory Commission:

“An independent regulator is one who is free from industry and political influence…Once you insert the White House into the process, you don’t have an independent regulator anymore.”

“If you aren’t independent of political and industry influence, then you are at risk of an accident,” Macfarlane warned.

Statement by Dr. Gregory Jaczko, former Chairman of the U.S. Nuclear Regulatory Commission:

Gregory Jaczko, who led the NRC under President Obama, said Trump’s executive orders look like someone asked an AI chatbot, “How do we make the nuclear industry worse in this country?”

He called the orders a “guillotine to the nation’s nuclear safety system” that will make the country less safe, the industry less reliable and the climate crisis more severe.

Statement by Joseph Romm, a senior research fellow at the University of Pennsylvania’s Center for Science, Sustainability and the Media:

…any reduction in capacity at the NRC would be ill-timed with the administration’s proposed ramp-up of nuclear projects.

“This is not the time to be weakening oversight,” said Romm, who was a senior official at the Department of Energy in the 1990s. “It’s very dangerous to be weakening and undermining and politicizing the Nuclear Regulatory Commission’s oversight at a time when it’s not going to be having to do less work.”

Speeding up the permitting process while accepting proposals for new reactor designs would be “ridiculous and very dangerous,” he added.

Statement by Johanna Neumann, Environment America Research & Policy Center’s senior director of the Campaign for 100% Renewable Energy:

“Do we really want to create more radioactive waste to power the often dubious and questionable uses of AI?”

 

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